I’m very delighted that you have shown interest in my enterprise. Data protection is of a particularly high priority for the management of the „Sphinx Games – Henning Poehl“. The use of the Internet pages of the „Sphinx Games – Henning Poehl“ is possible without any indication of personal data; however, if a data subject wants to use special enterprise services via my website, processing of personal data could become necessary. If the processing of personal data is necessary and there is no statutory basis for such processing, I generally obtain consent from the data subject.
The processing of personal data, such as the name, address, e-mail address, or telephone number of a data subject shall always be in line with the General Data Protection Regulation (GDPR), and in accordance with the country-specific data protection regulations applicable to the „Sphinx Games – Henning Poehl“. By means of this data protection declaration, my enterprise would like to inform the general public of the nature, scope, and purpose of the personal data I collect, use and process. Furthermore, data subjects are informed, by means of this data protection declaration, of the rights to which they are entitled.
As the controller, the „Sphinx Games – Henning Poehl“ has implemented numerous technical and organizational measures to ensure the most complete protection of personal data processed through this website. However, Internet-based data transmissions may in principle have security gaps, so absolute protection may not be guaranteed. For this reason, every data subject is free to transfer personal data to me via alternative means, e.g. by telephone.
The data protection declaration of the „Sphinx Games – Henning Poehl“ is based on the terms used by the European legislator for the adoption of the General Data Protection Regulation (GDPR). my data protection declaration should be legible and understandable for the general public, as well as my customers and business partners. To ensure this, I would like to first explain the terminology used.
The website of the „Sphinx Games – Henning Poehl“ collects a series of general data and information when a data subject or automated system calls up the website. This general data and information are stored in the server log files. Collected may be (1) the browser types and versions used, (2) the operating system used by the accessing system, (3) the website from which an accessing system reaches my website (so-called referrers), (4) the sub-websites, (5) the date and time of access to the Internet site, (6) an Internet protocol address (IP address), (7) the Internet service provider of the accessing system, and (8) any other similar data and information that may be used in the event of attacks on my information technology systems.
When using these general data and information, the „Sphinx Games – Henning Poehl“ does not draw any conclusions about the data subject. Rather, this information is needed to (1) deliver the content of my website correctly, (2) optimize the content of my website as well as its advertisement, (3) ensure the long-term viability of my information technology systems and website technology, and (4) provide law enforcement authorities with the information necessary for criminal prosecution in case of a cyber-attack. Therefore, the „Sphinx Games – Henning Poehl“ analyzes anonymously collected data and information statistically, with the aim of increasing the data protection and data security of my enterprise, and to ensure an optimal level of protection for the personal data we process. The anonymous data of the server log files are stored separately from all personal data provided by a data subject.
On the website of the „Sphinx Games – Henning Poehl“, users are given the opportunity to subscribe to my enterprise’s newsletter. The input mask used for this purpose determines what personal data are transmitted, as well as when the newsletter is ordered from the controller.
The „Sphinx Games – Henning Poehl“ informs its customers and business partners regularly by means of a newsletter about enterprise offers. The enterprise’s newsletter may only be received by the data subject if (1) the data subject has a valid e-mail address and (2) the data subject registers for the newsletter shipping. A confirmation e-mail will be sent to the e-mail address registered by a data subject for the first time for newsletter shipping, for legal reasons, in the double opt-in procedure. This confirmation e-mail is used to prove whether the owner of the e-mail address as the data subject is authorized to receive the newsletter.
The website of the „Sphinx Games – Henning Poehl“ contains information that enables a quick electronic contact to my enterprise, as well as direct communication with me, which also includes a general address of the so-called electronic mail (e-mail address). If a data subject contacts the controller by e-mail or via a contact form, the personal data transmitted by the data subject are automatically stored. Such personal data transmitted on a voluntary basis by a data subject to the data controller are stored for the purpose of processing or contacting the data subject. There is no transfer of this personal data to third parties.
The „Sphinx Games – Henning Poehl“ offers users the possibility to leave individual comments on individual blog contributions on a blog, which is on the website of the controller. A blog is a web-based, publicly-accessible portal, through which one or more people called bloggers or web-bloggers may post articles or write down thoughts in so-called blogposts. Blogposts may usually be commented by third parties.
Each data subject shall have the right granted by the European legislator to obtain from the controller the confirmation as to whether or not personal data concerning him or her are being processed. If a data subject wishes to avail himself of this right of confirmation, he or she may, at any time, contact me as the controller.
If a data subject wishes to avail himself of this right of access, he or she may, at any time, contact me as the controller.
If a data subject wishes to exercise this right to rectification, he or she may, at any time, contact me as the controller.
If one of the aforementioned reasons applies, and a data subject wishes to request the erasure of personal data stored by the „Sphinx Games – Henning Poehl“, he or she may, at any time, contact me as the controller. „Sphinx Games – Henning Poehl“ shall promptly ensure that the erasure request is complied with immediately.
Where the controller has made personal data public and is obliged pursuant to Article 17(1) to erase the personal data, the controller, taking account of available technology and the cost of implementation, shall take reasonable steps, including technical measures, to inform other controllers processing the personal data that the data subject has requested erasure by such controllers of any links to, or copy or replication of, those personal data, as far as processing is not required. „Sphinx Games – Henning Poehl“ will arrange the necessary measures in individual cases.
If one of the aforementioned conditions is met, and a data subject wishes to request the restriction of the processing of personal data stored by the „Sphinx Games – Henning Poehl“, he or she may at any time contact me as the controller. „Sphinx Games – Henning Poehl“ will arrange the restriction of the processing.
The „Sphinx Games – Henning Poehl“ shall no longer process the personal data in the event of the objection, unless I can demonstrate compelling legitimate grounds for the processing which override the interests, rights and freedoms of the data subject, or for the establishment, exercise or defence of legal claims.
If the „Sphinx Games – Henning Poehl“ processes personal data for direct marketing purposes, the data subject shall have the right to object at any time to processing of personal data concerning him or her for such marketing. This applies to profiling to the extent that it is related to such direct marketing. If the data subject objects to the „Sphinx Games – Henning Poehl“ to the processing for direct marketing purposes, the „Sphinx Games – Henning Poehl“ will no longer process the personal data for these purposes.
In addition, the data subject has the right, on grounds relating to his or her particular situation, to object to processing of personal data concerning him or her by the „Sphinx Games – Henning Poehl“ for scientific or historical research purposes, or for statistical purposes pursuant to Article 89(1) of the GDPR, unless the processing is necessary for the performance of a task carried out for reasons of public interest.
If the decision (1) is necessary for entering into, or the performance of, a contract between the data subject and a data controller, or (2) it is based on the data subject’s explicit consent, the „Sphinx Games – Henning Poehl“ shall implement suitable measures to safeguard the data subject’s rights and freedoms and legitimate interests, at least the right to obtain human intervention on the part of the controller, to express his or her point of view and contest the decision.
If the data subject is logged in at the same time on Facebook, Facebook detects with every call-up to my website by the data subject—and for the entire duration of their stay on my Internet site—which specific sub-site of my Internet page was visited by the data subject. This information is collected through the Facebook component and associated with the respective Facebook account of the data subject. If the data subject clicks on one of the Facebook buttons integrated into my website, e.g. the „Like“ button, or if the data subject submits a comment, then Facebook matches this information with the personal Facebook user account of the data subject and stores the personal data.
For the web analytics through Google Analytics the controller uses the application „_gat. _anonymizeIp“. By means of this application the IP address of the Internet connection of the data subject is abridged by Google and anonymised when accessing my websites from a Member State of the European Union or another Contracting State to the Agreement on the European Economic Area.
The purpose of the Google Analytics component is to analyze the traffic on my website. Google uses the collected data and information, inter alia, to evaluate the use of my website and to provide online reports, which show the activities on my websites, and to provide other services concerning the use of my Internet site for us.
Google Analytics places a cookie on the information technology system of the data subject. The definition of cookies is explained above. With the setting of the cookie, Google is enabled to analyze the use of my website. With each call-up to one of the individual pages of this Internet site, which is operated by the controller and into which a Google Analytics component was integrated, the Internet browser on the information technology system of the data subject will automatically submit data through the Google Analytics component for the purpose of online advertising and the settlement of commissions to Google. During the course of this technical procedure, the enterprise Google gains knowledge of personal information, such as the IP address of the data subject, which serves Google, inter alia, to understand the origin of visitors and clicks, and subsequently create commission settlements.
If a data subject reaches my website via a Google ad, a conversion cookie is filed on the information technology system of the data subject through Google. The definition of cookies is explained above. A conversion cookie loses its validity after 30 days and is not used to identify the data subject. If the cookie has not expired, the conversion cookie is used to check whether certain sub-pages, e.g, the shopping cart from an online shop system, were called up on my website. Through the conversion cookie, both Google and the controller can understand whether a person who reached an AdWords ad on my website generated sales, that is, executed or canceled a sale of goods.
The data and information collected through the use of the conversion cookie is used by Google to create visit statistics for my website. These visit statistics are used in order to determine the total number of users who have been served through AdWords ads to ascertain the success or failure of each AdWords ad and to optimize my AdWords ads in the future. Neither my company nor other Google AdWords advertisers receive information from Google that could identify the data subject.
The conversion cookie stores personal information, e.g. the Internet pages visited by the data subject. Each time you visit my Internet pages, personal data, including the IP address of the Internet access used by the data subject, is transmitted to Google in the United States of America. These personal data are stored by Google in the United States of America. Google may pass these personal data collected through the technical procedure to third parties.
If the data subject is logged in on YouTube, YouTube recognizes with each call-up to a sub-page that contains a YouTube video, which specific sub-page of my Internet site was visited by the data subject. This information is collected by YouTube and Google and assigned to the respective YouTube account of the data subject.
If the data subject selects the „purchase on account“ or „installment purchase“ during the ordering process in my online shop as a payment option, the data of the data subject is automatically transmitted to Klarna. By selecting one of these payment options, the data subject agrees to this transmission of personal data required for the processing of the invoice or installment purchase, or identity and creditworthiness checks.
If the data subject chooses „immediate transfer“ as the payment option in my online shop during the ordering process, the data of the data subject will be transmitted to Sofortüberweisung. By selecting this payment option, the data subject agrees to the transmission of personal data required for payment processing.
Where the processing of personal data is based on Article 6(1) lit. f GDPR my legitimate interest is to carry out my business in favor of the well-being of all.
Before personal data is provided by the data subject, the data subject must contact me. I clarifies to the data subject whether the provision of the personal data is required by law or contract or is necessary for the conclusion of the contract, whether there is an obligation to provide the personal data and the consequences of non-provision of the personal data.
If you have questions about data protection or if you want us to delete your data, you can also use this e-mail in addition to the usual contact options: privacy-policy@sphinx-games.com.