Privacy Policy

I. General information

1. Responsible body, introduction

We are Torpor Games UG (haftungsbeschränkt), based at Rheinsberger Str. 76/77 c/o Factory Works GmbH, Berlin and you can reach us by post or e-mail at contact@torporgames.com.

The protection of your privacy is very important to us. We therefore explain below which personal data we collect and process when you use our services or make use of our offers. Personal data are individual details about personal or factual circumstances of a specific or identifiable natural person. This includes, for example, the name, e-mail address or telephone number.

The collection, processing (including storage, modification, transmission, blocking and deletion) and use of your data is carried out in compliance with the provisions of data protection law. Personal data is only collected, used and passed on if this is permitted by law or if users give their consent to the collection of data and if this is technically or legally necessary for the provision of the service. Under no circumstances will the data collected be sold or unlawfully passed on to third parties for any other reason.

2. Legal basis

We collect and process personal data based on the following legal bases:

- Consent according to Article 6 paragraph 1 lit. a General Data Protection Regulation (GDPR). Consent is any voluntary expression of intent, in an informed and unequivocal manner, in the form of a statement or other unambiguous confirmatory act, which indicates that the data subject consents to the processing of his personal data.

- Necessity to fulfill the contract or carry out preparatory actions in accordance with Article 6 para. 1 lit. b GDPR, this means that the data is required so that we can fulfill the contractual obligations to you or we need the data to prepare a contract closure with you.

- Processing to fulfill legal obligations under Article 6 para. 1 lit. c GDPR, this means that a processing of the data is required by law or other regulations.

- Processing for the protection of legitimate interests in accordance with Article 6 para. 1 lit. f GDPR, this means that processing is necessary to safeguard legitimate interests on our part or by third parties, unless the interests or fundamental rights and freedoms on your part that require the protection of personal data prevail.

We store and access information in your terminal equipment based on the following legal bases:

- Consent pursuant to Section 25 para.1 of the Telecommunications and Digital Services Data Protection Act (TDDDG).

- Absolute necessity according to Section 25 para. 2 no. 2 TDDDG, so that we can provide a digital service expressly requested by you.

3. Rights of Affected

You are entitled to the following rights with regard to the processing of data by us in accordance with the respectively listed articles of the General Data Protection Regulation:

Information Right pursuant to Article 15 GDPR, i.e. the right to be informed about how your personal data is processed and which personal data is processed by us,

Right of rectification pursuant to Article 16 GDPR - i.e. the right to request the rectification of inaccurate personal data relating to you without undue delay, including the completion of incomplete data,

Right to erasure ("right to be forgotten") pursuant to Article 17 GDPR - i.e. the right to request the erasure of your personal data, provided that certain conditions are met,

Right to restriction of processing pursuant to Article 18 GDPR - i.e. the right to request the restriction of the processing of your personal data, provided that certain conditions are met,

Right to data portability pursuant to Article 20 GDPR - i.e. the right to demand that you receive your personal data that you have provided in a structured, common and machine-readable format and the right to transfer it to a third party, provided that certain conditions are met,

Right to object in accordance with Article 21 GDPR - i.e. the right to object to the processing of your personal data where the processing is based on our legitimate interests, provided that certain conditions are met.

Without prejudice to any other administrative or judicial remedy, you shall have the right to complain to a supervisory authority, in particular in the Member State of your place of residence, employment or the place of the alleged infringement, if you believe that the processing of the personal data is violating the GDPR.

4. Data erasure and storage duration

The personal data of the data subject will be deleted or blocked as soon as the purpose of the storage is deleted. In addition, storage may take place if provided for by the European or national legislator in EU regulations, laws or other regulations to which the controller is subject. Blocking or deletion of the data also takes place if a storage period prescribed by the standards mentioned expires, unless there is a need for further storage of the data for conclusion of a contract or fulfillment of the contract.

II. Specific data processing

1. Provision of customer support

a) Scope of data processing

By sending an email to our customer support (contact@torporgames.com) you agree to provide us with certain personal information including your email.

We use the services of Google LLC to process this data. The service provider is prohibited from any other use. The provider is based in the United States of America.

b) Legal basis

The legal basis for the processing of the data is Art. 6 para. 1 lit. a) and lit. f) GDPR.

The legal basis for the transfer of data to Google LLC is Art. 28 para. 3, 6 in conjunction with Art. 46 para. 2 lit. c) GDPR by means of the standard clauses of the EU Commission and Art. 45 para. 1 GDPR by means of the EU-U.S. Data Privacy Framework (10 July 2023). Google LLC is certified accordingly (https://www.dataprivacyframework.gov/list).

The legitimate interest lies in responding to the support enquiry.

c) Purpose of the data processing

The purpose of processing the e-mail address and other personal data is to facilitate customer service, e.g. to help the player. The service provider serves as a tool for managing the messages and processes the data on our behalf.

d) Duration of storage

Your data will be deleted when we no longer need your data to provide support.

e) Possibility of objection and removal

You can request the deletion of your user data at any time by post or by e-mail to contact@torporgames.com without incurring any further costs.

2. Provision of a user account

a) Scope of data processing

If you play the game, we create a user account with a unique UserID to allocate your game data (name, player name, platform used, email, profile picture etc.). To process this data, we use services from Apple Inc. (Apple Sign-In) and Google LLC (Google Sign-In and Firebase Authentication). The service providers are prohibited from any further use. The providers are based in the United States of America.

b) Legal basis

The legal basis for the processing of the data is Art. 6 para. 1 lit. b) GDPR and Section 25 para. 2 no. 2 TDDDG. The legal basis for the transfer of data to Google LLC is Art. 28 para. 3, 6 in conjunction with Art. 46 para. 2 lit. c) GDPR by means of the standard clauses of the EU Commission and Art. 45 para. 1 GDPR by means of the EU-U.S. Data Privacy Framework (10 July 2023). Google LLC is certified accordingly (https://www.dataprivacyframework.gov/list). The legal basis for the transfer of data to Apple Inc. is Art. 28 para. 3, 6 in conjunction with Art. 46 para. 2 lit. c) GDPR by means of the standard clauses of the EU Commission.

For this purpose, access to information already stored by you on your end device is absolutely necessary so that we can make the user account available as an integral part of the game.

c) Purpose of the data processing

The purpose of the processing is to provide the game and respective accounts.

d) Duration of storage

The data is stored until the user account is deleted.

e) Possibility of objection and removal

You can request the deletion of your user account at any time by mail or by e-mail to contact@torporgames.com without incurring any further costs.

3. Leaderboard, game statistics and save games

a) Scope of data processing

If you play the game, your game data and statistics will be saved and processed by presenting this game data to you and the other players of the game on a leaderboard. The provision of the leaderboard may be associated with the editing and deletion of game data. This is the case, for example, if the game data is related to a technical error. To process this data, we use services (Google Play Games Services, Firebase Firestore and Firebase Storage) from Google LLC. The service provider is prohibited from any further use. The provider is based in the United States of America.

b) Legal basis

The legal basis for the processing of the data is Art. 6 para. 1 lit. b) GDPR and Section 25 para. 2 no. 2 TDDDG. The legal basis for the transfer of data to Google LLC. is Art. 28 para. 3, 6 in conjunction with Art. 46 para. 2 lit. c) GDPR by means of the standard clauses of the EU Commission and Art. 45 para. 1 GDPR by means of the EU-U.S. Data Privacy Framework (10 July 2023). The service provider is certified accordingly (https://www.dataprivacyframework.gov/list).

For this purpose, access to information already stored on your device is absolutely necessary so that we can provide save games and the leaderboard as an integral part of the game.

c) Purpose of the data processing

The purpose of the processing is to provide save games and a leaderboard to the players of the game.

d) Duration of storage

The data is stored for the duration of the provision of the save games and leaderboard or until the user initiates deletion.

e) Possibility of objection and removal

You can request the deletion of your game data at any time by post or by e-mail to contact@torporgames.com without incurring any further costs.

4. Sharing game data using Rich Presence

If you play the game, your game data (playing time, game mode, etc.) will be processed by sharing the game data with your friends (contacts) or other users using the Rich Presence function. The processing is carried out by the Valve Corporation, P.O. Box 1688, , Bellevue, WA 98004, USA for Steam. The scope and legal basis for processing by Valve Corporation can be found in their data protection information: https://store.steampowered.com/privacy_agreement/?snr=100601_44_44_

You can prevent the sharing of data using Rich Presence by rejecting the collection. You can do this in the options menu of Steam.

5. Use of our Discord server

a) Scope of data processing

We operate a server with the Discord service of Discord Netherlands BV. This allows users to communicate with each other in writing or via voice chat and exchange content. The data processing by Discord takes place on the basis of the necessary contract with Discord itself. The scope and legal basis for processing by Discord can be found in their data protection information:

https://discord.com/privacy

We ourselves do not have access to the Discord database and can only moderate the respective channels editorially and exclude users from using them.

b) Legal basis

The legal basis for processing is your consent in accordance with Art. 6 para. 1 lit. a) GDPR. There is joint responsibility with Discord in accordance with Art. 26 GDPR.

c) Purpose of the data processing

The purpose is to exchange information about our game with you and other players.

d) Duration of storage

The storage period of posts is determined by Discord in its privacy policy.

e) Possibility of objection and removal

You can delete your messages or your customer account on Discord yourself at any time or contact the contact point specified in Discord's privacy policy. If you wish to delete posts, you can also contact us at contact@torporgames.com

6. Use of Steam

The use of our game requires the use of the "Steam" service provided by Valve Corporation, P.O. Box 1688, , Bellevue, WA 98004, USA and Valve S.a.r.l., Regus City Centre Suite 227, 26 Boulevard Royal, L-2449 Luxembourg, Luxembourg ("Valve") and the conclusion of a user agreement with Valve. Valve itself collects personal data in the context of the use of the "Steam" service in its own name and on the basis of this user agreement. We have no access to this data. With regard to the collection and use of data by "Steam", we therefore refer you to Valve's user agreement and privacy policy. These can be found here: https://store.steampowered.com/privacy_agreement/?snr=100601_44_44_

7. Social media presence

a) Scope of data processing

We maintain publicly accessible profiles on various social networks. Your visit to these profiles triggers a variety of data processing operations. These data processing operations may be necessary for individual functionalities of our profiles in social networks. These functionalities will not be available to you, or only to a limited extent, if you do not provide us with your personal data. When you visit our profiles, your personal data is not only collected, used and stored by us, but also by the operators of the respective social network. This happens even if you yourself do not have a profile on the respective social network. The individual data processing operations and their scope differ depending on the operator of the respective social network and they are not necessarily traceable by us. For details on the collection and storage of your personal data as well as the type, scope and purpose of its use by the operator of the respective social network, please refer to the data protection declarations of the respective operator:

The privacy policy for the social network Instagram, which is operated by Meta Platforms Ireland Limited, can be viewed at https://help.instagram.com/155833707900388;
The privacy policy for the social network X, which is operated by Twitter International Unlimited Company, One Cumberland Place, Fenian Street, Dublin 2, Ireland, can be viewed at https://twitter.com/en/privacy;
The privacy policy for the social network YouTube, which is operated by Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland, can be viewed at https://policies.google.com/privacy?hl=en;
the privacy policy for the social media presence Twitch, which is operated by Twitch Interactive, Inc., 350 Bush Street, 2nd Floor, San Francisco, CA 9410, can be viewed at https://www.twitch.tv/p/en/legal/privacy-notice/;
The privacy policy for the social network LinkedIn, which is operated by LinkedIn Ireland Unlimited Company, Wilton Place, Dublin 2, Ireland, can be viewed at https://www.linkedin.com/legal/privacy-policy
the privacy policy for the social network Reddit, which is operated by Reddit Netherlands B.V., Euro Business Center, Keizersgracht 62, 1015CS Amsterdam, Netherlands, can be viewed at https://www.reddit.com/policies/privacy-policy.

We do not have access to the databases of social media providers.

b) Legal basis

The legal basis for the processing of the data is Art. 6 para. 1 lit. f) GDPR. This data processing serves our (and your) legitimate interest in enabling dialogue with you and other players about our game and improving the user experience when visiting our fan page in a target group-specific manner.

There is joint responsibility with the social media providers in accordance with Art. 26 GDPR.

c) Purpose of the data processing

The purpose is to exchange information with you and other players about our game and to improve the user experience when visiting our social media presence for specific target groups.

d) Duration of storage

The storage duration of data processing operations on our social media presences is determined by the respective data protection regulations of the social media providers.

e) Possibility of objection and removal

You can delete your messages or your customer account on the social media sites yourself at any time or contact the contact points specified in the data protection declarations of the social media providers.

8. Analytics

a) Scope of data processing

As part of the use of our game, we use analytics functions to enable you to access the game smoothly and to constantly improve your gaming experience. We collect with our own software (Torpor Analytics Service) and through service providers information about how you use the game and compile various statistics. The usage data collected includes in particular the device ID (MAC/IMEI/MEID), which is pseudonymised, the device type, the country, the device language, the installed operating system, the language settings, the CPU type and the number of CPUs, information on the graphics card, system and video RAM, the current screen resolution, in-game behaviour, IP address, platform (e.g. iOS, Android or Steam). In the event of technical errors, the error report (crash logs) and the error message are also recorded. To process this data, we use the folloing services: Unity Cloud Diagnostics from Unity Technologies ApS and Firebase Analytics from Google LLC. Google LLC is based in the United States of America.

b) Legal basis

The legal basis for the processing of the data for use for analysis purposes is Art. 6 para. 1 lit. a) GDPR and Section 25 para. 1 TDDDG. The legal basis for the transfer of data to Google LLC is Art. 28 para. 3, 6 in conjunction with Art. 46 para. 2 lit. c) GDPR by means of the standard clauses of the EU Commission and Art. 45 para. 1 GDPR by means of the EU-U.S. Data Privacy Framework (10 July 2023). Google LLC is certified accordingly (https://www.dataprivacyframework.gov/list).

The legal basis for the transfer of data to Unity Technologies ApS is Art. 28 para. 3, 6 in conjunction with Art. 46 para. 2 lit. c) GDPR by means of the standard clauses of the EU Commission.

c) Purpose of the data processing

The purpose of analysing user behaviour is to optimise and eliminate errors in the game offering with regard to the expectations and use by customers and to ensure that the game runs smoothly.

d) Duration of storage

The processed data will be stored by us up to 365 days or until you withdraw your consent.

e) Possibility of objection and removal

You can request the deletion of your user data at any time by post or by e-mail to contact@torporgames.com without incurring any further costs. In the event of an objection by e-mail, the implementation of the deletion or blocking may take up to 5 working days, unless we are legally obliged (e.g. to clarify payment disputes) to store the data for a longer period. You can prevent the storage of data by rejecting its collection. You can do this when we ask for your consent or later in the options menu of the game.

9. Mobile advertising

a) Scope of data processing

In our game, we use advertising technologies to display personalized or contextual ads. For this purpose, we and our service providers collect and process data such as:

Device ID
IP address
Device type and model
Operating system and version
Language and country settings
App usage behavior
Ad interactions (e.g. impressions, clicks, installs)

This data may be used to create pseudonymous user profiles and to deliver targeted advertising. The following advertising and mediation services are used:

Google AdMob from Google LLC. The provider is based in the United States of America;
AppLovin Mediation from AppLovin Corporation. The provider is based in the United States of America;
Meta Audience Network Mediation from Meta Platforms Ireland Ltd;
Unity Ads Android & iOS Mediation from Unity Technologies ApS;
ironSource Android & iOS Ads Mediation from ironSource Mobile Ltd. The provider is based in Israel.

b) Legal basis

The legal basis for the processing of the data for use for advertising purposes is Art. 6 para. 1 lit. a) GDPR and Section 25 para. 1 TDDDG.

The legal basis for the transfer of data to AppLovin Corporation is Art. 28 para. 3, 6 in conjunction with Art. 46 para. 2 lit. c) GDPR by means of the standard clauses of the EU Commission and Art. 45 para. 1 GDPR by means of the EU-U.S. Data Privacy Framework (10 July 2023). Google LLC is certified accordingly (https://www.dataprivacyframework.gov/list).

The legal basis for the transfer of data to Meta Platforms Ireland Ltd is Art. 28 para. 3, 6 in conjunction with Art. 46 para. 2 lit. c) GDPR by means of the standard clauses of the EU Commission.

The legal basis for the transfer of data to Unity Technologies ApS is Art. 28 para. 3, 6 in conjunction with Art. 46 para. 2 lit. c) GDPR by means of the standard clauses of the EU Commission.

The legal basis for the transfer of data to ironSource Mobile Ltd is Art. 28 para. 3, 6 in conjunction with Art. 46 para. 2 lit. c) GDPR by means of the standard clauses of the EU Commission.

c) Purpose of the data processing

The purpose of processing is to display relevant advertisements, measure the effectiveness of advertising campaigns, finance the free use of the game through ad revenue

d) Duration of storage

The processed data will be stored by us up to 26 months or until you withdraw your consent.

e) Possibility of objection and removal

10. Epic Online Services

a) Scope of data processing

If you play the game, your data required for cross-platform services (user ID and session metadata such as timestamps, region, player statistics) will be processed. To process this data, we use Epic Online Services (EOS) from Epic Games, Inc. Epic Games, Inc. is based in the United States of America. Epic Games, Inc. itself describes its data processing activities here https://www.epicgames.com/site/en-US/privacypolicy.

b) Legal basis

The legal basis for the processing of the data is Art. 6 para. 1 lit. b) GDPR and Section 25 para. 2 no. 2 TDDDG. The legal basis for the transfer of data to Epic Games, Inc. is Art. 28 para. 3, 6 in conjunction with Art. 46 para. 2 lit. c) GDPR by means of the standard clauses of the EU Commission.

For this purpose, access to information already stored by you on your end device is absolutely necessary so that we can provide the cross-platform services as an integral part of the game.

c) Purpose of the data processing

The purpose of the processing is to provide cross-platform services.

d) Duration of storage

The data is stored for the duration of a session and up to 90 days after the end of the session.

e) Possibility of objection and removal

There is no option to object when using cross-platform services.

11. SquareSpace Website RSS Feed

a) Scope of data processing

When using our game, we use services from Squarespace Domains LLC to provide you with RSS content (in-game news). The data processed includes in particular the IP address, the user-agent and logs of requested content to provide you with in-game news. Squarespace Domains LLC is based in the United States of America.

b) Legal basis

The legal basis for the processing of the data is Art. 6 para. 1 lit. b) GDPR and Section 25 para. 2 no. 2 TDDDG. The legal basis for the transfer of data to Squarespace Domains LLC is Art. 28 para. 3 in conjunction with Art. 45 para. 1 GDPR by means of the EU-U.S. Data Privacy Framework (10 July 2023). Squarespace Inc. is certified accordingly (https://www.dataprivacyframework.gov/list). Only if the EU-U.S. Data Privacy Framework is not adequate, the transfer of data will be based on Art. 28 para. 3, 6 in conjunction with Art. 46 para. 2 lit. c) GDPR by means of the standard clauses of the EU Commission.

For this purpose, access to information already stored by you on your end device is absolutely necessary so that we can provide RSS content as an integral part of the game.

c) Purpose of the data processing

The purpose of the processing is to provide RSS content within the game.

d) Duration of storage

The data is stored for the duration of 30 days.

e) Possibility of objection and removal

There is no option to object.

12. Use of GOG

The use of our game requires the use of the "GOG" service provided by GOG Spółka z ograniczoną odpowiedzialnością, JAGIELLOŃSKA 74, 03-301 WARSAW, POLAND ("GOG") and the conclusion of a user agreement with GOG. GOG itself collects personal data in the context of the use of the "GOG" service in its own name and on the basis of this user agreement. We have no access to this data. With regard to the collection and use of data by GOG, we therefore refer you to GOG’s privacy policy. These can be found here: https://support.gog.com/hc/en-us/articles/212632109-Privacy-Policy?product=gog

13. Achievements (Steam and GOG)

a) Scope of data processing

If you play the game, your game data may be processed for the purpose of tracking and displaying achievements and sharing your progress with friends or other users via platform-specific features. This includes the processing of:

Achievement unlock timestamps
Achievement IDs
User interactions

For Steam, this processing is carried out by Valve Corporation. The scope and legal basis for processing by Valve Corporation can be found in their privacy policy: https://store.steampowered.com/privacy_agreement/?snr=100601_44_44_

For GOG, achievements and related data are processed by GOG Spółka z ograniczoną odpowiedzialnością via the GOG platform. The scope and legal basis for processing by GOG can be found in their privacy notice:

https://support.gog.com/hc/en-us/articles/360023620554-GOG-GALAXY-Privacy-notice?product=gog

b) Legal basis

The legal basis for the processing of the data is Art. 6 para. 1 lit. b) GDPR, as it is necessary for the performance of the contract to provide game functionality.

c) Purpose of the data processing

The purpose of processing is to track and display player achievements

d) Duration of storage

The data storage duration is is determined by the respective data protection regulations of the respective platform.

e) Possibility of objection and removal

You may request the deletion of your account or specific data through the respective platform’s privacy settings or support channels. Please note that deletion of achievement data may affect your game experience and visibility of progress.

14. Newsletter dispatch

a) Scope of data processing

It is possible to subscribe to a free newsletter on our website or in our game, which contains direct advertising for our products or the products of our cooperation partners. When registering for the newsletter, the data from the input mask is transmitted to us or the e-mail address already stored is used. In this case, the date and time of registration for the newsletter and the IP address used will also be stored. As part of the confirmation of the newsletter registration, the date and time at which you click on the confirmation link for the newsletter registration and the IP address used are also stored. If you have consented to this, we use a web beacon to record the opening and clicking behaviour with regard to the respective newsletter in anonymised form when the newsletter is opened.

When sending the newsletter, your e-mail address will be forwarded to the external service provider Mailchimp operated by Rocket Science Group LLC, who will be responsible for sending the newsletter on our behalf. Any further use is not made by the service provider. The service provider is located outside the European Union in the United States of America.

b) Legal basis

The legal basis for processing the data when registering directly for the newsletter is Art. 6 para. 1 (a) GDPR and Section 25 para. 1 TDDDG.

The legal basis for the transfer of the data to our newsletter service providers is Art. 28 para. 3, 6 GDPR in connection with the use of the Standard Contractual Clauses of the EU-Commission.

c) Purpose of the data processing

The purpose of storing the e-mail address is to enable electronic contact for advertising purposes. The date and IP address of the registration and the confirmation of the registration are recorded in order to document the consent to the newsletter dispatch in a verifiable manner and to exclude misuse.

The opening and click behaviour for the newsletter is recorded in order to improve our newsletter dispatch.

The data is passed on to the service provider for the purpose of sending the newsletter in bulk. The service provider does not have the right to use the data for its own purposes beyond this.

d) Duration of storage

We will only delete or block the e-mail address for sending advertising if you revoke your consent. The data used to confirm the newsletter subscription will be stored for the same period of time.

e) Possibility of objection and removal

You can object to the use of your e-mail address for advertising purposes or withdraw your consent at any time without incurring any costs over and above the charges for your communication tariff. You can object to the use of your e-mail address for advertising purposes with effect for the future by clicking on a link provided in each advertising mailing. You can also send an e-mail to: contact@torporgames.com to object to the use of advertising with effect for the future or to revoke your consent. In the event of an objection by e-mail, the cancellation or blocking may take up to 5 working days; advertising may still be sent during this period.

15. Firebase Cloud Messaging

a) Scope of data processing

We use Firebase Cloud Messaging (FCM), a service provided by Google LLC, to send targeted push notifications to users of our mobile application. For this purpose, we process push-notification tokens (FCM tokens). These tokens are device-specific and allow the app to deliver messages to the correct recipient.

b) Legal basis

c) Purpose of the data processing

The purpose of processing is to send targeted push notifications to users based on their preferences and app usage.

d) Duration of storage

The data is stored until the push token is invalidated due to expiration or deinstallation of the game.

e) Possibility of objection and removal

You can withdraw your consent to receive push notifications at any time via the app settings or your device’s notification settings. After withdrawal, no further push notifications will be sent, and the associated token will no longer be used.

16. Firebase Remote Config

a) Scope of data processing

We use Firebase Remote Config, a service provided by Google LLC, to dynamically adjust features and content in our game. For this purpose, the processed data includes in particular: device identifiers (e.g. user IDs and device IDs) during fetch requests and configuration parameter keys and values

This allows us to remotely control app behavior and conduct A/B testing without requiring users to update the app.

b) Legal basis

The legal basis for the processing of the data to adjust features and content in our game is Art. 6 para. 1 lit. b) GDPR and Section 25 para. 2 no. 2 TDDDG. The legal basis for the processing of the data for use for A/B testing is Art. 6 para. 1 lit. a) GDPR and Section 25 para. 1 TDDDG. The legal basis for the transfer of data to Google LLC is Art. 28 para. 3, 6 in conjunction with Art. 46 para. 2 lit. c) GDPR by means of the standard clauses of the EU Commission and Art. 45 para. 1 GDPR by means of the EU-U.S. Data Privacy Framework (10 July 2023). Google LLC is certified accordingly (https://www.dataprivacyframework.gov/list).

For the adjustment of features and content in our game, access to information already stored by you on your end device is absolutely necessary.

c) Purpose of the data processing

The purpose of processing is to dynamically control app features and to conduct A/B testing to evaluate and improve user experience and app performance

d) Duration of storage

The data is stored for up to 12 hours.

e) Possibility of objection and removal

You can withdraw your consent to the use of Firebase Remote Config for A/B testing at any time via the game’s privacy settings. After withdrawal, no further data will be collected for this purpose. For the purpose of dynamically controlling app features there is no option to object.

17. Google Play Billing

a) Scope of data processing

We use Google Play Billing, a service provided by Google LLC, to process in-app purchases and verify transactions. For this purpose, the processed data includes in particular: Google Account ID (hashed), Purchase token, Product ID, Purchase timestamp, IP address and the device ID.

b) Legal basis

The legal basis for the processing is Art. 6 para. 1 lit. b) and c) GDPR in connection with German tax and trade laws and Section 25 para. 2 no. 2 TDDDG. The legal basis for the transfer of data to Google LLC is Art. 28 para. 3, 6 in conjunction with Art. 46 para. 2 lit. c) GDPR by means of the standard clauses of the EU Commission and Art. 45 para. 1 GDPR by means of the EU-U.S. Data Privacy Framework (10 July 2023). Google LLC is certified accordingly (https://www.dataprivacyframework.gov/list).

For the processing of in-app purchases, verification of transactions, and fulfilment of legal obligations related to financial reporting and fraud prevention, access to information already stored by you on your end device is absolutely necessary.

c) Purpose of the data processing

The purpose of processing is to process in-app purchases, verify transactions, and fulfill legal obligations related to financial reporting and fraud prevention.

d) Duration of storage

The data is stored as required for tax and accounting purposes.

e) Possibility of objection and removal

You may request the deletion of your Google Account or specific purchase data through your Google Account settings. Please note that certain data may be retained for legal reasons even after account deletion.

18. Unity In-App Purchasing (IAP)

a) Scope of data processing

We use Unity IAP, a service provided by Unity Technologies ApS, to process in-app purchases and verify transactions. For this purpose, the processed data includes in particular: Product ID, Transaction ID Purchase timestamp, user ID and the device ID.

b) Legal basis

c) Purpose of the data processing

The purpose of processing is to process in-app purchases, verify transactions, and fulfill legal obligations related to financial reporting and fraud prevention.

d) Duration of storage

The data is stored as required for tax and accounting purposes.

e) Possibility of objection and removal

You may request the deletion of your specific purchase data by sending an e-mail to: contact@torporgames.com. Please note that certain data may be retained for legal reasons even after a deletion request.

Last update: 30.05.2025