Privacy Policy

1. Responsible Person

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 regulations is ViewMedia.

2. General Information on Data Protection

The protection of your personal data is of particular concern to us. We therefore process your data exclusively on the basis of the statutory provisions (GDPR). In this privacy policy, we inform you about the most important aspects of data processing in the context of our website and the WENGLA app.

This privacy policy applies both to the use of our website (https://viewmedia.eu) and to the WENGLA app, which is available in the Apple and Google app stores.

2.1 Principles of Data Processing

We process personal data in accordance with the following principles:

• Lawfulness, processing in good faith, transparency: all data processing is lawful, fair and transparent.
• Purpose limitation: Data is only collected for specified, explicit and legitimate purposes.
• Data minimization: Only the data that is necessary for the respective purpose is processed.
• Correctness: We ensure that incorrect data is corrected or deleted immediately.
• Storage limitation: Data is only stored for as long as is necessary for the purpose.
• Integrity and confidentiality: Appropriate data security through technical and organizational measures.

3. Data Processing on the Website

3.1 Automatic Data Collection When Visiting the Website

Each time you visit our website, information is automatically transmitted from your device's browser to our server and stored in log files.

Data collected:

• IP address of the accessing computer
• Date and time of access
• Name and URL of the accessed file
• Website from which the access was made (referrer URL)
• Browser used and, if applicable, the operating system of your computer and the name of your access provider
• Amount of data transferred
• Notification of successful retrieval

Legal basis: Art. 6 para. 1 lit. f GDPR (legitimate interest)
Purpose: This data is used to ensure a trouble-free connection to the website, system security and stability and to optimize our website.
Storage period: The log files are automatically deleted after 30 days.

3.2 Cookies

Our website uses cookies. Cookies are small text files that are stored on your end device and saved by your browser.

3.2.1 Technically Necessary Cookies

These cookies are required for the basic functions of the website.

• Session cookies: Enable navigation on the website
• Login cookies: Save login information for the forum
• Security cookies: Protection against cross-site request forgery attacks

Legal basis: Art. 6 para. 1 lit. f GDPR (legitimate interest)
Storage period: Session cookies are deleted after closing the browser, other technical cookies after a maximum of 30 days.

3.2.2 Functional Cookies

These cookies improve the user-friendliness of the website.

• Language settings: Saving the selected language
• Design preferences: Saving of display settings

Legal basis: Art. 6 para. 1 lit. a GDPR (consent)
Storage period: Up to 12 months

3.3 Newsletter System

When you register for our newsletter, we process the following data:

Data collected:

• E-mail address (mandatory field)
• Name (optional)
• Time of registration
• IP address at the time of registration
• Confirmation status of the registration

Legal basis: Art. 6 para. 1 lit. a GDPR (consent)
Purpose:

• Sending information about WENGLA updates
• Notifications about new features
• Information about events and tournaments
• Marketing communication

Procedure: We use the double opt-in procedure. After registering, you will receive a confirmation e-mail with a link that you must click on to confirm your registration.

Storage period: Until you withdraw your consent or unsubscribe from the newsletter.

Revocation: You can revoke your consent at any time by:

• Using the unsubscribe link in every newsletter email
• Send an e-mail to newsletter@viewmedia.eu
• Communicate your deregistration via the contact form

4. Data Processing in the WENGLA App

4.1 Account Creation and Player Data

Registration is required to participate in tournaments and use all app functions.

Data collected during registration:

• User name (mandatory field)
• Email address (mandatory field)
• Password (stored in encrypted form)
• Date of birth (for age verification)
• Country/Region
• Device information (device type, operating system, app version)
• Unique device ID
• Registration date and time

Legal basis: Art. 6 para. 1 lit. b GDPR (fulfillment of contract)
Purpose:

• Provision of the game functionality
• Participation in tournaments and events
• Administration of prizes and winnings
• Protection against fraud and multiple accounts
• Age verification for tournaments with prizes

4.2 Gaming Activities and Statistics

While using the app, we collect various gaming data.

Data collected:

• Game statistics (wins, losses, points)
• Game progress and history
• Tournament participations and results
• In-app purchases and virtual currency
• Friends lists and social interactions
• Chat messages (moderated)
• Game time and usage behavior
• Device performance data

Legal basis: Art. 6 para. 1 lit. b GDPR (fulfillment of contract)
Purpose:

• Game progress and rankings
• Matchmaking and balancing
• Fraud protection and fair play
• Improvement of the gaming experience
• Technical optimization of the app

4.3 In-app Purchases and Payment Data

Transaction data is processed for in-app purchases.

Data collected:

• Purchased items and quantities
• Transaction IDs
• Time of the purchases
• Payment method (via App Store/Google Play)
• Billing address (if required)

Legal basis: Art. 6 para. 1 lit. b GDPR (fulfillment of contract)
Purpose:

• Processing of purchases
• Provision of the purchased content
• Invoicing and accounting
• Fraud protection

Note: The actual payment processing takes place via the app stores (Apple App Store, Google Play Store). We do not receive complete payment details such as credit card numbers.

5. Data Transmission to Third Parties

5.1 App Store Provider

When you use the app, data is transmitted to the respective app store providers:

Apple App Store:

• Apple Inc, One Apple Park Way, Cupertino, CA 95014, USA
• Data protection declaration: https://www.apple.com/privacy/

Google Play Store:

• Google LLC, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA
• Data protection declaration: https://policies.google.com/privacy

Transmitted data: Download information, usage statistics, crash reports, in-app purchase data
Legal basis: Art. 6 para. 1 lit. b GDPR (fulfillment of contract)

6. Your Rights as a Data Subject

You have the following rights regarding your personal data:

6.1 Right of Access (Art. 15 GDPR)

You have the right to obtain information about the personal data processed by us. The information includes in particular:

• Processing purposes
• Categories of personal data
• Recipients or categories of recipients
• Planned storage period
• Existence of further rights

6.2 Right to Rectification (Art. 16 GDPR)

You have the right to request the rectification of inaccurate personal data or the completion of incomplete personal data.

6.3 Right to Erasure (Art. 17 GDPR)

You have the right to erasure of your personal data if:

• The data is no longer required for the original purposes
• You have withdrawn your consent
• The data has been processed unlawfully
• The deletion is necessary to fulfill legal obligations

6.4 Right to Restriction of Processing (Art. 18 GDPR)

You have the right to request the restriction of processing if:

• The accuracy of the data is contested
• The processing is unlawful, but you oppose erasure
• We no longer need the data, but you need it for legal prosecution
• You have lodged an objection and it has not yet been determined whether our interests prevail

6.5 Right to Data Portability (Art. 20 GDPR)

You have the right to receive the personal data concerning you in a structured, commonly used and machine-readable format and to transmit those data to another controller.

6.6 Right to Object (Art. 21 GDPR)

You have the right to object, on grounds relating to your particular situation, at any time to processing of personal data concerning you which is based on point (e) or (f) of Article 6(1) GDPR.

6.7 Right to Withdraw Consent (Art. 7 para. 3 GDPR)

If the processing is based on consent, you have the right to withdraw this consent at any time. The revocation does not affect the legality of the processing carried out until the revocation.

6.8 Right to Lodge a Complaint (Art. 77 GDPR)

You have the right to complain to a data protection supervisory authority about the processing of your personal data by us.

Responsible supervisory authority in Germany:
Federal Commissioner for Data Protection and Freedom of Information
Graurheindorfer Str. 153, 53117 Bonn
Phone: +49 (0)228-997799-0
Email: poststelle@bfdi.bund.de

7. Storage Period

We only store personal data for as long as is necessary for the respective purposes or for as long as statutory retention periods apply.

7.1 General Storage Periods

• Website log files: 30 days
• Newsletter data: Until consent is withdrawn
• App accounts: Until the account is deleted
• Contact requests: 3 years
• Tournament/competition data: 10 years (tax retention obligation)
• Invoice data: 10 years (retention obligation under commercial law)

7.2 Automatic Deletion

We have implemented automatic deletion processes that ensure that data is automatically deleted after the storage periods have expired.

8. Protection of Minors

8.1 Age Verification

The WENGLA app and website are aimed at users aged 13 and over. For tournaments with real prizes, participation is only possible from the age of 16 (with the consent of a parent or guardian) or from the age of 18.

8.2 Special Protective Measures

Special protective measures apply to underage users:

• Restricted communication options
• Increased moderation of chat content
• No processing of special categories of personal data
• Restricted data processing for marketing purposes

8.3 Rights of Legal Guardians

Legal guardians can at any time:

• Request information about the data processing of their child
• Request the deletion of their child's data
• Object to further data processing

9. Changes to the Privacy Policy

We reserve the right to amend this privacy policy in order to adapt it to changed legal situations or in the event of changes to the service and data processing. However, this only applies with regard to declarations on data processing. If the user's consent is required or components of the privacy policy contain provisions of the contractual relationship with the users, the changes will only be made with the consent of the users.

Users are requested to inform themselves regularly about the content of the privacy policy. The current version is always available at https://viewmedia.eu/privacy

We will process your request immediately and within one month at the latest.