Privacy Policy for Reporting Illegal Content
Lotum GmbH (4 Pics 1 Word) and Lotum one GmbH (Word Blitz, Quiz Planet), Am
Goldstein 1, 61231 Bad Nauheim, Germany, games@lotum.de (“Lotum” or “we”)
respect and protect your personal data.
With the following privacy policy, we would like to inform you in more
detail about the collection, processing and use of data in connection with
the form for reporting illegal content.
Scope of Application
This privacy policy is aimed at all users of the form for reporting illegal
content.
As far as certain Lotum services have a different privacy policy, then that
policy applies.
The scope of this Privacy Policy does not include services and offers of
third parties that may be referred to in the Games App by so-called links.
Lotum neither assumes responsibility for their content nor for compliance
with data protection regulations by these third parties, unless otherwise
stated in the privacy policy of the linked content. This applies, for
example, to links via which social networks such as Facebook or chat apps
such as WhatsApp can be accessed, and to links in advertisements that are
played. For information on the handling of the User's personal data and
their respective protection on these platforms, please refer to the privacy
statement on the respective platform.
Notice and action mechanisms
We are required by law to establish a procedure by which individuals or
entities can notify the presence of individual information in our services
that you consider to be illegal content.
According to Art. 16 para. 2 DSA, we are obliged to take measures to include
the following information:
a) a sufficiently substantiated explanation of the reasons why the
individual or entity alleges the information in question to be illegal
content;
b) a clear indication of the exact electronic location of that information;
c) the name and email address of the individual or entity submitting the
notice, except in the case of information considered to involve one of the
offences referred to in Articles 3 to 7 of Directive 2011/93/EU;
d) a statement confirming the bona fide belief of the individual or entity
submitting the notice that the information and allegations contained therein
are accurate and complete.
In accordance with Art. 16 (4) and (5) DSA, we will send you a confirmation
of receipt after submission and notify you of our decision regarding the
reported content by email once this has been made. Your email address
collected in the notification form will be used exclusively for the purpose
of processing the notification. The basis for the processing of your
personal data as part of the notice and action mechanism is Art. 6 (1)
sentence 1 lit. c) GDPR in conjunction with Art. 16 DSA.
Support requests and contact via the games app
If you notify our customer support or otherwise contact us (e.g. with a
contact form in the Games App), the information you provide in the contact,
including the contact details given there, will be processed for the purpose
of handling your enquiry and processing it, including investigating and
rectifying any problems in the Games App and in the event of follow-up
questions. In the event of a request to our customer support via the Games
App, information on the Games App, your game progress, Player-ID and, if
applicable, the problematic part of the game as well as technical data on
your device will also be processed automatically.
If you notify our customer support or otherwise contact us (e.g. via the
contact form), the information you provide when contacting us (game, Support
ID, email address), will be processed for the purpose of handling your
enquiry and processing it, including in the event of follow-up questions.
We process this data in accordance with Art. 6 (1) sentence 1 lit. b) GDPR,
if you contact us within the scope of an existing contract for the use of
the Games App or for the purpose of initiating such a contractual
relationship. If you contact us regarding the reporting of individual
information that you consider to be illegal content, the processing is
carried out in accordance with Art. 6 (1) lit. c) GDPR in conjunction with
Art. 16 DSA. Otherwise, this storage and use of data is based on Art. 6 (1)
sentence 1 (f) GDPR, whereby our legitimate interest is the thorough
processing of your respective request and the solution of any technical
problems. Access to the data stored in your end device is absolutely
necessary in accordance with § 25 (2) no. 2 TTDSG so that Lotum can answer
your (support) request.
Transmission to Third Parties
Personal data will only be transferred to third parties without the User's
explicit consent if this is necessary for the provision of Lotum's services
(e.g. for the technical provision of the offer), unless stated otherwise at
another point in this Privacy Policy. Accordingly, a transfer of data to
such service providers (such as technical service providers) only takes
place in order to protect our legitimate interests pursuant to Article 6 (1)
sentence 1 lit. f) GDPR. Of course, Lotum will ensure that the respective
service provider has taken appropriate technical and organizational measures
to guarantee the security of the data before forwarding the User's personal
data.
Apart from that, Lotum will not pass on the User's personal data to third
parties, unless the User has expressly consented to the transfer (Article 6
(1) sentence 1 lit. a) GDPR) and Lotum is neither entitled nor obliged to
transfer the data due to legal regulations or court orders. In the latter
case, Lotum will transfer the data in order to fulfill a legal obligation
according to Article 6 (1) sentence 1 lit. c) GDPR.
User Rights
Right to Object
The user has the right to object at any time to data processing based on
Art. 6 (1) lit. e) or lit. f) GDPR for reasons arising from his particular
situation, unless Lotum can prove compelling reasons worthy of protection,
which outweigh the interests of the user, or the processing serves to
assert, exercise or defend legal claims. The user can object to data
processing for the purpose of direct advertising at any time without special
reasons being required.
Right to Access
The user has the right to obtain free of charge from Lotum the personal data
stored by Lotum concerning him or her, the processing purposes, their
origin, which transfer to which recipients or categories of recipients took
place, the storage period and the rights of the data subjects available to
him or her.
Right to Correction, Deletion And/or Restriction of Data Processing
Furthermore, the user has the right to request at any time the correction of
incorrect data, the deletion and/or restriction of the processing of
personal data stored about him or her, insofar as there is no legal
obligation for Lotum to keep records or other reasons in the sense of Art.
17 (3) GDPR which prevents deletion. Insofar as this includes personal data
that is necessary for the provision of services to the user, the deletion or
restriction of the processing of this data can only take place when the user
no longer uses Lotum's services.
Right to Data Portability
If the user provides data relating to him or her and Lotum processes such
data on the basis of the user's consent or in order to fulfill the contract,
the user may request that he/she receives such data in a structured, current
and machine-readable format from Lotum or that Lotum transmits such data to
another controller, insofar as this is technically possible (so-called right
to data portability).
Right to Revoke Consent
Any consent given by the user to the use of personal data can be freely
revoked by the user at any time with effect for the future.
Right to Complain to a Supervisory Authority
The user may also lodge a complaint with a supervisory authority against
data processing which he or she considers to be in breach of the statutory
provisions.
Changes to the Privacy Policy
Lotum reserves the right to change this privacy policy at any time, while
Lotum will always comply with the legal requirements of data protection.
Therefore, Lotum recommends that users regularly take note of the applicable
privacy policy. Lotum will inform users in advance of any further use of
data, for example via in-game notification or so-called push notifications
in your browser, if you allow such push notifications.
Data Protection Officer of Lotum One GmbH: Susanne Klein, c/o Beiten
Burkhardt Services GmbH, Ganghoferstraße 33, 80339 München, Germany,
privacy@lotum.de