Privacy policy
This privacy policy applies to the website www.8bitonion.de and to the app “Shifter Under Us” (Android and iOS). This is a translation for convenience; in case of discrepancies, the German version prevails.
1. Controller
Ihab Basaleh – 8 Bit OnionWeserstr. 2, 12047 Berlin, Germany
Email: info@8bitonion.de
No data protection officer has been appointed, as there is no legal obligation to do so. For privacy questions, please contact us at the address above.
Part A – Website2. Hosting and server log files
This website is hosted by IONOS SE, Elgendorfer Str. 57, 56410 Montabaur, Germany. When you visit the website, information sent by your browser is automatically stored in server log files:
- IP address
- date and time of access
- requested page or file and amount of data transferred
- referrer URL (previously visited page)
- browser and operating system
This processing is technically necessary to deliver the website and to ensure its security and stability (e.g. defending against attacks). The legal basis is Art. 6(1)(f) GDPR; our legitimate interest is the secure and error-free operation of the website. We have concluded a data processing agreement with IONOS under Art. 28 GDPR. Log files are automatically deleted or anonymised after a short period.
3. Contact form and email
If you write to us via the contact form or by email, we process the data you provide (name, email address, content of your message) to answer your request. Messages from the form are delivered to us by email via IONOS servers.
The legal basis is Art. 6(1)(b) GDPR where your request relates to a contract or pre-contractual measures, and otherwise Art. 6(1)(f) GDPR (our legitimate interest in answering enquiries). We delete your data once your request has been fully dealt with, unless statutory retention obligations apply.
4. No cookies, no tracking, local fonts
This website does not set cookies, does not use analytics or tracking services and does not embed third-party content. Fonts are loaded directly from our own server; there is no connection to Google Fonts or other external services.
5. Encryption
For security reasons, this website uses SSL/TLS encryption. You can recognise an encrypted connection by “https://” in your browser's address bar.
Part B – App “Shifter Under Us”6. General information about the app
“Shifter Under Us” does not require a user account. Before playing, you choose a player name freely – please do not use your full real name. The app currently has no chat or voice features. Should this change, we will update this privacy policy.
The app is intended for people aged 16 and over.
7. Download via app stores
When you download the app via Google Play (Google Ireland Limited) or the Apple App Store (Apple Distribution International Ltd.), these providers process data such as your account details, device identifiers and payment information under their own responsibility. We have no influence on this; the privacy policy of the respective store applies.
8. Online multiplayer (Photon Fusion)
For online play we use the Photon Fusion service of Exit Games GmbH, Hongkongstr. 7, 20457 Hamburg, Germany. To allow players to join a room and play together, the following is processed:
- IP address (to establish the connection)
- your freely chosen player name
- the room code
- the game state (e.g. roles, actions and votes during a match)
This data is only needed to run the game session. The legal basis is Art. 6(1)(b) GDPR (providing the game feature you use) and Art. 6(1)(f) GDPR (stable and secure operation). More information: Photon privacy policy.
9. Advertising (Unity LevelPlay)
The app is free and financed by advertising. To serve ads we use the mediation platform Unity LevelPlay (formerly ironSource) of Unity Technologies SF, 116 New Montgomery Street, Suite 200, San Francisco, CA 94105, USA (EU contact: Unity Technologies ApS, Niels Hemmingsens Gade 24, 1153 Copenhagen, Denmark), and the ad networks connected through it:
- Unity Ads (Unity Technologies) – privacy policy
In particular, the following data may be processed: your device's advertising ID (Google Advertising ID or Apple IDFA), IP address, device information (e.g. model, operating system, language, carrier) and usage data on ads shown and clicked.
Consent
On first launch, the app asks whether you consent to personalised advertising. We only show personalised ads with your consent (Art. 6(1)(a) GDPR, § 25(1) TDDDG). Without consent you receive non-personalised ads; the legal basis for this is our legitimate interest in financing the free game (Art. 6(1)(f) GDPR).
You can withdraw or change your consent at any time with effect for the future in the app's settings. You can also reset or disable the advertising ID in your device settings.
Transfers to third countries
Unity and some ad networks also process data outside the EU, in particular in the USA and Israel. For Israel, an adequacy decision of the European Commission exists. Transfers to the USA are based on the EU-US Data Privacy Framework where the recipient is certified, and otherwise on the European Commission's standard contractual clauses (Art. 46(2)(c) GDPR).
More information: Unity privacy policy for game players.
10. iOS: App Tracking Transparency
On iOS devices, the app uses Apple's “App Tracking Transparency” prompt to ask whether it may track you across apps and websites. The app only gets access to the advertising ID (IDFA) if you agree. You can change this at any time under Settings › Privacy & Security › Tracking.
11. Local storage on your device
The app stores your player name, your settings (e.g. sound) and your privacy choice on your device so you don't have to enter them every time. This data does not leave your device (the player name is only transmitted during an online match, see no. 8). The legal basis is § 25(2) no. 2 TDDDG and Art. 6(1)(b) GDPR. Uninstalling the app removes this data.
Part C – Retention and your rights12. Retention
We only store personal data for as long as necessary for the respective purpose or as required by statutory retention periods. After that, it is deleted.
13. Your rights
Under the GDPR you have the following rights:
- access to your stored data (Art. 15 GDPR)
- rectification of inaccurate data (Art. 16 GDPR)
- erasure (Art. 17 GDPR)
- restriction of processing (Art. 18 GDPR)
- data portability (Art. 20 GDPR)
- objection to processing (Art. 21 GDPR)
- withdrawal of consent with effect for the future (Art. 7(3) GDPR)
Right to object
Where we process data on the basis of Art. 6(1)(f) GDPR, you may object at any time on grounds relating to your particular situation.
To exercise your rights, simply email info@8bitonion.de.
14. Right to lodge a complaint
You have the right to lodge a complaint with a data protection supervisory authority. The authority responsible for us is:
Berliner Beauftragte für Datenschutz und Informationsfreiheit (Berlin Commissioner for Data Protection and Freedom of Information)Alt-Moabit 59–61, 10555 Berlin, Germany
www.datenschutz-berlin.de
15. Obligation to provide data
You are not obliged to provide us with personal data. However, without the technically necessary connection data (nos. 2 and 8), the website or the online game cannot be used.