This policy tells you:
- What information we might collect about you
- How we might use that information
- What information of yours we might share with others
- Your choices about the personal information you give us
1. THE INFORMATION WE COLLECT
We receive both Information that is directly provided to us – such as personal information you provide when you visit our website, use our app or participate in an activity on the Service – and information that is passively or automatically collected from you – such as usage information collected from your browser or device.
Information You Provide To Us: In order to participate in an activity on the Service, for example, a competition or other similar activity, you may be required to provide some contact information such as name and email address and other information such as a photograph or a video, depending on the specific activity. Additional details on collecting and processing will be provided at the point of collection and by the specific terms for participating in that activity.
Information That Is Passively Or Automatically Collected: We also receive information that is automatically collected from your browser or device when you visit the Service, such as page views, clicks, IP address, device type and the type of browser you are using.
Information We Receive From Third Parties: When you engage with our content through social media or any other Da Vinci Media sites or applications, you may allow those sites to share Information with us; such as content you have viewed or interacted with, and adverts which you have been shown or clicked on within the content.
The individual privacy policies for these sites and applications will contain more detail and give specific information on how to change your privacy settings.
2. PROTECTION OF YOUR PERSONAL INFORMATION
We’re strongly committed to keeping you and your family’s information safe. To do this we design our services with your safety in mind. We also have dedicated team roles to look after your Information security and privacy.
However, no service can be completely secure. If you have any concerns that your Da Vinci account or personal information has been put at risk, for example if someone could have found out your password, please get in touch straight away by email at: firstname.lastname@example.org
3. HOW WE USE YOUR INFORMATION
We use your information in four ways:
3.1 To fulfil a contract, or take steps linked to a contract pursuant to Article 6(1)(b) of Regulation (EU) 2016/679 (“GDPR”):
- To provide the Service and to communicate with you about your account with us where we offer registration.
- To send you information about changes to our terms or policies.
- To allow you to take part in any competitions that we run from time to time, administer the competition, notify you if you have won, verify your identity, residency and other eligibility requirements as applicable, deliver the prize and respond to any query you may have about the competition.
3.2 Where this is necessary for purposes which are in our, or third parties’, legitimate interests pursuant to Article 6(1)(f) of GDPR:
These interests are:
- To fulfil your requests and inquiries regarding the Service;
- To provide technical support (including testing, quality assurance, troubleshooting and security) for the Service.
- To analyze how the Service is used, including search queries, frequency of viewing and length of viewing time, page views and clicks, to help us manage and improve the Service and to develop new services.
- To manage the delivery of advertising, including the number of times the same advertisement is served and viewed.
- To run a survey or market research on the Service to understand our audience; and protecting the safety of our users.
3.3. Where you give us consent pursuant to Article 6(1)(a) of GDPR:
- To send you newsletters about our products, services and events available in your region and to use technologies to check if these have been received and opened, in accordance with the additional information provided at the point of collecting your consent.
- To deal with your requests, complaints and enquiries.
- To contact you about various things such as competition winners.
3.4. For purposes which are required by law pursuant to Article 6(1)(c) of GDPR;
- In response to requests by government or law enforcement authorities conducting an investigation.
- To comply with our legal obligations.
4. RETENTION OF YOUR INFORMATION
Where we offer registration, we keep details of users who have registered with us for as long as you use the Service and your user account details for up to 18 months afterwards. We delete user profile information provided to us for the Service automatically when the registration for the Service is cancelled.
If you contact us with support queries, we keep the data for between 3 and 18 months, depending on the nature of the query and whether you have registered with us.
Where we process Information for marketing purposes, we process the Information while you remain interested in the marketing (for example, where you open and read our offers) and for three years after that point. If you ask us to stop sending marketing we will keep your Information for a short period after this (to allow us to implement your requests).
Where we process Information for a competition, we keep the data for 12 months from the day the competition ends unless a longer period is required by law.
4.1 Where we store your information:
Some companies that provide services to us run their services from outside the European Economic Area. We only let that happen if we are satisfied with their levels of security. Keep in mind that when you give us personal information it could be transferred, stored or processed in a location outside the EEA.
5. INFORMATION SHARING
We do not disclose any personal information about children to third parties.
We do not share identifiable adult personal information with third parties other than where it is necessary to administer the services we have agreed to provide you. Any such information shared will be with appropriate security measures, to carefully selected third parties only, including service providers we engage to perform functions on our behalf, such as hosting or operating our Sites and sending email communications.
We may also disclose your information to third parties:
- If our or substantially all of our assets are acquired by a third party, in which case personal data held by us about our customers will be one of the transferred assets;
When we share your information we will always share it in a secure way and require such third parties to not use your personal information for their own business purposes, unless you have explicitly consented to the use of your personal information in this way.
- We collect product analytics data using a 3rd party analytics software called Mixpanel. The data collected here is strictly for the use by Da Vinci Media GmbH, the app owner, to understand the product usage by our customers and to use this data for improving the product/service we deliver to our customers.
- We collect your email address with your consent, for verification of your authenticity, providing customer support, and unlocking special in-app functionalities that enable multi-device portability such as game badges & achievements, favorites etc.
- We communicate marketing messages only to you if you have performed a double opt-in by verifying your email and agreed to receive such messages.
- We may also use your email address in ad-tools such as Facebook and AdWords to create look-alike audiences for which we use Da Vinci Media GmbH’s personal ad publisher accounts and not 3rd party/external accounts/partners.
You have the right at any time to ask us not to share any of your personal information with third parties by contacting us at email@example.com and opting out.
6. COOKIES AND SIMILAR TRACKING
7. YOUR RIGHTS
You have a number of rights in relation to your personal data:
- You have the right to ask us for a copy of your Information, to correct, delete or restrict (stop any active) processing of your Information; and to obtain the Information you provided to us.
- In addition, as far as the processing of your Information is based on our, or third parties’, legitimate interest, you have the right to object to the processing of your information.
- These rights may be limited, for example if fulfilling your request would reveal Information about another person, or if you ask us to delete Information which we are required by law to keep or have compelling legitimate interests in keeping.
- You can withdraw your consent in respect of any processing of personal data which is based upon a consent which you have previously provided.
- You can opt out of receiving email newsletters and any other marketing communications by following the opt-out instructions provided to you in those emails.
- You also have a right to complain to a supervisory authority for data protection in the country where you live, where you work, or where you consider that a breach of data protection has occurred, although we hope that we can assist with any queries or concerns you may have about our use of your Information.
We update this policy from time to time. If we make important changes, such as how we use your personal information, we’ll let you know. This notification can be a notice, an email, or a message in your app.
If you don’t agree to the changes, then you can always stop using our services, delete your account and stop giving us any more personal information. We’d be sorry to see you go.
9. HOW TO CONTACT US
For any other questions or comments about this policy speak to our Data Protection Officer:
Dr. Lukas Mezger
- by email at: firstname.lastname@example.org
- by post to: Da Vinci Media GmbH, Mehringdamm 55, D-10961 Berlin
Impressum / Imprint
Da Vinci Media GmbH
10961 Berlin – Germany.
vertreten durch den Managing Director/ represented by Managing Director:
HRB 106731 B AG Charlottenburg
USt-ID: DE 814863625
Tel. +49  4050 468 -0
Fax +49  4050 468 -16
Redaktion/ Kontakt: webmaster (at) davincitv (dot) net
Verantwortlich für den Inhalt i.S.d / responsible for content according to § 5 TMG i.V.m. § 55 RStV: