Name and address of the controller
The controller within the meaning of the General Data Protection Regulation (GDPR) and other national data protection laws of the member states as well as other data protection provisions is:
Hersfelder Straße 21-23
60487 Frankfurt am Main
Tel.: 069-780 780
-following: "Rawbet", "we", "us"-
A General information on data processing
1. Functioning of the platform
Rawbet is a social gaming platform. We enable console players to meet through the app and compete against pre-determined stakes for money and other prizes in different game formats (e.g. duels, tournaments, leaderboards etc.) (hereinafter referred to as "Skill Games"). The respective user must be registered with a compatible streaming provider and have an active account there. If desired, the respective opponents can be assigned to the player using an algorithm based on the player's previous game results and the skill level calculated from these results. Players can also search and invite each other to games and view the results of players from their friends list.
2. Recipients of personal data / transfer personal data to a third country
Only those persons who need access to your personal data in order to fulfil our contractual and legal obligations and to protect our legitimate interests are granted access.
Under these conditions, recipients of your personal data are:
· Public bodies and institutions based in the EU in case of a legal or official obligation.
· Contract processor:
In order to fulfil our contractual obligations, we work together with other companies, so-called Processors. These are each named in the following data protection information. In this context, personal data will only be passed on to the service companies mentioned above for the purpose of processing personal data by this service provider on our behalf and on the basis of our instructions (so-called "data processing"), insofar as this is necessary to provide our services and to safeguard our legitimate interests. The processors are subject to contractual obligations to implement appropriate technical and organisational measures to protect your personal data and process your personal data exclusively in accordance with our instructions.
· Transfer of personal data to a third country:
The personal data that Rawbet processes about you may be transferred and processed to recipients located inside or outside the European Economic Area who do not ensure an adequate level of data protection. The third countries that provide an adequate level of data protection from a European data protection law perspective are Andorra, Argentina, Canada, Switzerland, Faroe Islands, Guernsey, Israel, Isle of Man, Jersey, New Zealand, Eastern Republic of Uruguay and Japan. If your personal data is transferred to countries that do not offer an adequate level of data protection from the point of view of EU law, Rawbet bases the respective transfer on appropriate guarantees, such as the standard data protection clauses adopted by the European Commission (Art. 46 para. 2 lit. c) DPA) or provides for other measures to guarantee a level of data protection comparable to that in Europe (Art. 46 DPA). We will gladly provide you with a copy of the corresponding warranty on request.
3. Data erasure and storage durationThe personal/personally identifiable data of the person concerned will be deleted as soon as the purpose of the storage no longer applies. Furthermore, data may be stored if this has been provided for by the European or national legislator in EU regulations, laws or other regulations to which our company is subject. The data is also deleted when a storage period prescribed by the aforementioned standards expires.
B Provision of the website and creation of log files
1. IP address und log files
Any time that ourweb pages or app (hereinafter collectively referred to as "Rawbet-Services") are accessed, our system automatically collects data and information from the device of the corresponding user.
The following data will be collected:
a) browser and operating system
b) the user's operating system
c) the IP address of the user
d) date and time of Access
e) websites from which the user's system accesses our website
f) Websites that are called up by the user's system via our website
g) Web pages that are called up by the user's system on our website
The data will bestored in the log files of our system. This data will not be stored together with other personal data of the user. The IP address as well as the information on the enquiry(s) of your internet browser is technically necessary for calling up and using the internet page; without processing of this data, internet page access cannot take place and internet pages cannot be displayed. The processing of the IP address is, after it is no longer technically necessary for the calling/use of the Internet offer, made anonymous or deleted by shortening.
The above-mentioned data are processed by us for the following purposes:
· ensure a smooth connection of the website,
· ensure a comfortable use of our website,
· evaluation of system security and stability and
· for other administrative purposes.
The legal basis for the processing is Art. 6 para. 1 sentence 1 lit. f DSGVO. The legitimate interest in the processing lies in the technical feasibility of calling up the Rawbet-Services, the optimised presentation of the content to the user and the future further improvement/optimisation of the Internet offering. For the right to object to data processing on the basis of Art. 6 para. 1 sentence 1 letter f DSGVO, see below ("Rights of data subjects").
Personal data will be deleted as soon as it is no longer necessary for the purpose for which it was collected. In the case of collection of personal data for website provision, this will bewhen the respective visit to our Rawbet-Services ends.
In the case of temporary storage of personal data in log files, this will be the case after 7 days at the latest.
The data stored by us will be stored via the Firebase cloud service, which is offered by the company Google LLC, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA ("Google Firebase"). Google Firebase uses servers located in the EEA for its services wherever possible. However, it cannot be ruled out that data may also be transferred to the USA. To ensure an adequate level of data protection, Google has subjected itself to the EU-US Privacy Shield (https://www.privacyshield.gov/participant?id=a2zt000000001L5AAI&status=Active). In addition, we have concluded a contract with Google under the Commission's standard data protection clauses, in which Google undertakes to process user data only in accordance with our instructions and to comply with the EU data protection level. The legal basis for the use of this cloud service is our legitimate interest in outsourcing data hosting (Art. 6 para. 1 lit. f DSGVO). For the right to object to data processing on the basis of Art. 6 para. 1 sentence 1 letter f DSGVO, see below ("Rights of data subjects").
You can find more information about Google Firebase and data protection here: https://firebase.google.com/terms/data-processing-terms; https://firebase.google.com/support/privacy/.
Cookies requiring consent, on the other hand, serve to record the use of our website and to evaluate it for the purpose of optimising our offer for you and to display information tailored to your needs (marketing and statistics cookies). The legal basis of data processing for cookies requiring consent is Article 6 paragraph 1 lit. a) DSGVO.
Most browsers automatically accept cookies. However, you can configure your browser so that no cookies are stored on your computer or so that a message always appears before a new cookie is created. However, disabling cookies completely may mean that you will not be able to use all the features of our website. The length of time cookies are stored depends on their intended use and is not the same for everyone.
We recommend that you always log off completely from shared computers that are set to accept cookies.
Cookies are stored on the user's computer and transmitted by the user to our website. Therefore, you as a user also have full control over the use of technically necessary cookies. By changing the settings in your browser, you can deactivate or restrict the transmission of technically necessary cookies. Cookies that have already been saved can be deleted at any time. This can also be done automatically. If technically necessary cookies for our website are deactivated, it is possible that not all functions of the website can be used to their full extent.
C Participation in Rawbet-Services
To use the Rawbet-Services you must first register a Rawbet account. The registration is done on our website and/or mobile application either via our Rawbet registration form (if available) or via an account with a Rawbet compatible streaming provider (e.g. Twitch). As part of the registration via a compatible streaming provider, you simply enter your valid login/registration data (hereinafter referred to as streaming login) in the respective form on our website and/or within a Rawbet application. We will then automatically receive the information required for registration from the respective streaming provider. We will retrieve the following information and save it to your Rawbet account:
Name, profile picture with your streaming provider, email address, username, email verified?
We also request the following information from you during registration or at a later date and save it to the Rawbet account:
If you register using the registration form, you must enter this data yourself during registration or subsequently in your user account.
The data is used to enable you to participate in our services and to provide our services to you. The legal basis is Art. 6 para. 1 lit. b) DSGVO.
We also use your contact details to inform you about current events and offers related to our services. This is done in accordance with Art. 6 Para. 1 Sentence 1 lit. f)DSGVO. The legitimate interest in the processing lies in the appropriate marketing of our services and the information of registered players about current offers. For the right to object to data processing on the basis of Art. 6 para. 1 sentence 1 letter f DSGVO, see below ("Rights of data subjects").
As part of the participation in Skill-Games, we also collect data on the frequency of participation of individual players in Skill-Games and their outcome and store this data on the player account. We use this data to process winnings, to track game scores in the event of complaints and to calculate the individual skill score, which is used to match players of approximately equal skill levels if the players so desire. This matching function is an integral part of our platform. The data is used to enable you to participate in our services and to provide our services to you. The legal basis is Art. 6 para. 1 lit. b) DSGVO.
2. Use of our services
If you use our services, you must stream the games you play through a compatible streaming provider. In this context we collect the following information in particular: Game rating, gamer tag of the participating players, clubs, game states. The streams are stored by us for as long as this is necessary for the purpose of traceability in the event of complaints. They will be deleted after 30 days at the latest, unless longer storage is not necessary due to an ongoing conflict.
The data is used to enable you to participate in our services and to provide our services to you and to ensure compliance with the applicable rules of conduct. The legal basis is Art. 6 para. 1 lit. b) DSGVO.
3. Embedding of streams-videos
Our Rawbet-Services include videos from compatible streaming providers used by players, showing the currently active games and making them available to every user of the website. The integration is done via embedding, so that ultimately only the videos published on the respective streaming platform are displayed through a window on our website and are publicly accessible.
The embedding of videos in our Rawbet-Services is done in the advanced privacy mode, which only sets cookies when a user clicks on the video and plays it. No cookie is set when a user simply visits a page with an embedded video.
In addition to the videos, we also publish the usernames of the participating players and the amounts bet in our Rawbet-Services.
· Livestream of currently running games
The videos are published on our website in accordance with Art. 6 para. 1 sentence 1 lit. f)DSGVO. The legitimate interest in the processing lies in the appropriate marketing of our offer and the participation of other interested players in the games running on our platform. For the right to object to data processing on the basis of Art. 6 para. 1 sentence 1 letter f DSGVO, see below ("Rights of data subjects").
a) Google Analytics
We use Google Analytics, a web analysis tool of Google Inc, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA ("Google") on our websites. Google Analytics uses "cookies", which are stored on your PC and which enable an analysis of your use of the website. The information generated by the cookie includes, for example, browser type/version, operating system used, screen resolution, referrer URL (the previously visited page), anonymised IP address of the accessing computer, time of the server request, duration of the visit to individual pages, files downloaded, videos viewed, advertising banners clicked on, orders placed, click paths, etc. You will receive more detailed information about the cookies used by Google here.
This information may be transferred to a Google server in the USA and stored there. Google is committed to complying with the EU-U.S. Privacy Shield Agreement on the collection, use and retention of personal data from EU member states, as published by the U.S. Department of Commerce. In addition, we have concluded a contract with Google under the Commission's standard data protection clauses, in which Google undertakes to process user data only in accordance with our instructions and to comply with the EU data protection level.
We use Google Analytics on our websites with an IP anonymisation tool with which your IP address recorded by Google Analytics is transmitted by Google within member states of the European Union or in other signatory states to the Agreement on the European Economic Area in a shortened and thus anonymised form.
Google uses the collected information on our behalf on the basis of an agreement concluded by us with Google to statistically evaluate the use of the website for us in aggregated form, to create reports on website activities and the behaviour of users on our website and to provide us with further analysis services associated with the website and its use. These reports are used to help us design our website and its content to meet our needs and to optimise it on an ongoing basis. The IP address transmitted by your browser within the framework of Google Analytics is not merged with other data from Google.
The maximum retention period we have chosen for data linked to cookies or user IDs and advertising IDs is 14 months. After this retention period has expired, the data is automatically deleted.
The saving of cookies can be prevented by changing the browser settings accordingly; otherwise, saved cookies can be deleted by you via your browser. This may mean that certain functions of the website you have called up cannot be used at all or not conveniently.
Incidentally, you can deactivate the Google Analytics function specifically using a browser add-on, which you can download from https://tools.google.com/dlpage/gaoptout. You will need to install this browser add-on. This will prevent analysis information from being sent to Google. Alternatively (e.g. for mobile applications), you can opt-out of cookies by clicking on the respectively labelled Button in your profile setting. You can set a so-called opt-out cookie, which prevents future data from being collected via Google Analytics. Please note, however, that if you delete the cookies in your browser settings, this opt-out cookie is also deleted and must be set again by you.
You will find extensive information from Google on data processing in connection with Google Analytics here.
The legal basis for the use of Google Analytics is Art. 6 para. 1 sentence 1 lit. f DSGVO. The legitimate interest in processing lies in the analysis of usage data in order to identify and eliminate errors on the basis of this knowledge and to carry out optimisations with regard to the design of our Rawbet services, also with regard to increasing the conversion rate.
Within the framework of our Rawbet-Services we use the analysis tool Adjust from adjust GmbH, Saarbrücker Str. 36, 10405 Berlin (hereinafter "adjust"). Adjust collects information about the use of our Rawbet-Services by users and presents it as anonymous evaluations and graphics about the number of visits, number of pages or opened app per user, etc. We use this information to optimize our Rawbet-Services based on the basic analysis and to design them according to your needs. Within the analysis adjust also uses your pseudonymous IDFA or Android ID as well as your anonymized IP and MAC address.
The collection, evaluation and use of the data can be deactivated for future websites at https://www.adjust.com/opt-out/. For mobile applications, analysis for the future can be deactivated at https://www.adjust.com/forget-device/.
The legal basis for the use of adjust is Art. 6 para. 1 sentence 1 lit. f DSGVO. The legitimate interest in the processing lies in the analysis of usage data in order to identify and eliminate errors on the basis of these findings and to make optimisations with regard to the design of our Rawbet services, also with regard to increasing the conversion rate.
5. Payments and Rawbet-Wallet
For the provision of the virtual Rawbet-Wallet, we work together with the service provider Euro Payment Group GmbH, Europa-Allee 52, 60327 Frankfurt am Main ("EPG"), which on the one hand handles the technical provision and processing of the virtual accounts and on the other hand handles the deposits and withdrawals of the users. In this context, EPG processes personal data on our instructions as a processor on the basis of an order processing agreement pursuant to Art. 28 DSGVO. We store in the Rawbet accounts of the players information about the payment transactions carried out and the payment method used as well as any proof of identity and payment data provided in the course of the payment transactions to enable deposits and withdrawals, to clarify complaints and to fulfill our legal obligations to prevent money laundering. The legal basis for this data processing to process payments is Art. 6 para. 1 sentence 1 lit. b DSGVO. The integration of EPG is based on our legitimate interest in outsourcing the processing of payments and technical implementation of virtual accounts (Art. 6 para. 1 sentence 1 lit. f DSGVO. For the right to object to data processing on the basis of Art. 6 para. 1 sentence 1 letter f DSGVO, see below ("Rights of data subjects").
When paying by credit card, or PayPal, your personal data (first and last name, e-mail address, credit card data, mobile phone number, if applicable, as well as data on your respective orders) are transferred to our external payment service provider for the purpose of processing the payment. The transfer of payment data is carried out in a secure and encrypted form. The payment service provider processes personal data in this context on our instructions as an order processor on the basis of an order processing agreement pursuant to Art. 28 DSGVO. The legal basis for the processing of payments is Art. 6 para. 1 sentence 1 lit. b DSGVO. The payment service providers are involved because of our justified interest in outsourcing the processing of payments (Art. 6 para. 1 sentence 1 lit. f DSGVO. For the right to object to data processing on the basis of Art. 6 para. 1 sentence 1 letter f DSGVO, see below ("Rights of data subjects").
"PayPal" (if available) If we offer payment via the online payment service provider PayPal, the following applies: The provider of this payment service is PayPal (Europe) S.à.r.l. et Cie, S.C.A., 22-24 Boulevard Royal, L-2449 Luxembourg (hereinafter "PayPal"). If you select PayPal as your payment method, you will be redirected to PayPal's website and the personal data you enter will be transmitted to PayPal in encrypted form. This usually includes your name, address, telephone number, IP address, email address or other information necessary to process your order, including information about your order. The processing of personal data is carried out by PayPal as the controller. Insofar as this is necessary for the fulfilment of the order, data may also be passed on to third parties by PayPal. For identity and credit assessment purposes, PayPal also transfers personal data to credit agencies, such as SCHUFA. Further information about data processing by PayPal can be found at https://www.paypal.com/de/webapps/mpp/ua/privacy-full?locale.x=de_DE.
Sofortüberweisung (as far as available):
As far as payment is made via Sofortüberweisung, the data is collected by Sofort GmbH, Theresienhöhe 12, 80339 Munich. This asks for the IBAN as well as PIN and TAN of your online banking account. During the ordering process, you will be automatically forwarded to the secure payment form of Sofort GmbH. Immediately afterwards, you will receive confirmation of the transaction. Thereupon we receive the transfer credit directly. More information about data processing by Sofort GmbH can be found at https://www.klarna.com/sofort/#cq-0 .
6. Communication system
On our website and in our applications there is the possibility to contact our support team via chat. You can use the live chat to chat with our support staff in almost real time. When starting the chat, personal data is collected (date and time of the call, browser type/version, IP address, operating system used, URL of the previously visited website, amount of data sent, first name, surname, e-mail address). Depending on the course of the conversation with our employees, further personal data may be collected in the chat, which you enter. The type of this data depends strongly on your request or the problem you describe to us.
All our employees have been and are trained on the subject of data protection and are instructed on the secure and confidential handling of customer data. All our employees are obliged to maintain confidentiality.
In the context of conflict resolution, the respective opponent may also take part in the chat (group chat). The information disclosed within the chat is then also accessible to the opponent.
The provision of the chat and the data processing required for this purpose is carried out in order to provide appropriate support, which is part of our contractual services. The legal basis for this data processing is Art. 6 para. 1 sentence 1 lit. b DSGVO.
7. Rights of the data subject
If personal data is processed, you are the data subject within the meaning of the DSGVO and you are entitled to the following rights against us as the controller:
In addition to the right to revoke your consent given to Rawbet at any time with effect for the future, you have the following further rights if the respective legal requirements are met:
· Right of access by the data subject about your personal data stored with us in accordance with Art. 15 EU-DSGVO,
· Right to rectification incorrect data or to complete correct data in accordance with Art. 16 EU-DSGVO,
· Right to erasure (‘right to be forgotten’)of your data stored with us in accordance with Art. 17 EU-DSGVO,
· Right to restriction of processingof your data in accordance with Art. 18 EU-DSGVO,
· Right to data portability according to Art. 20 EU-DSGVO.
8. Right to object to data processing based on a legitimate interest
If the processing of the data is based on Art. 6 para. 1 letter f) DSGVO ("legitimate interest"), you have the right according to Art. 21 DSGVO to object at any time to the processing of personal data concerning you for reasons arising from your particular situation.
In the event of an objection, Rawbet will no longer process the personal data unless the processing serves the purpose of asserting, exercising or defending legal claims or Rawbet can demonstrate compelling legitimate reasons for processing that outweigh the interests, rights and freedoms of the data subject. If the objection concerns data processing that is essential to Rawbet-Services, an objection may result in you no longer being able to participate in Rawbet-Services and your Rawbet account may be blocked.
This data protection information is subject to the status 21.July 2020 and may be amended in the future in order to adapt to changed circumstances, in particular to adapt to changes in legal requirements, official practice or jurisdiction.