Information on data protection
We take the protection of your personal data seriously and would like to inform you here about data protection in our company.
Within the scope of our responsibility under data protection law, the entry into force of the EU General Data Protection Regulation (Regulation (EU) 2016/679; hereinafter: “GDPR”) has imposed additional obligations on us to ensure the protection of personal data of the person affected by a processing operation (hereinafter, we also refer to you as “customer,” “user,” “you,” or “data subject”).
Insofar as we decide either alone or jointly with others on the purposes and means of data processing, this includes in particular the obligation to inform you transparently about the nature, scope, purpose, duration, and legal basis of the processing (cf. Art. 13 and 14 DSGVO). With this declaration (hereinafter: “data protection notice”), we want to do just that.
Our data protection notices have a modular structure. They consist of a general part for all processing of personal data and processing situations that come into play each time a website is called up (I. General) and a special part, the content of which relates in each case only to the processing situation specified there with the designation of the respective offer or product, in particular the visit to our website (II.A. Visit to our website) and the use of our ryddle walking tour (II.B. ryddle walking tour), which are described in more detail here.
Following the model of Art. 4 DSGVO, this data protection notice is based on the following definitions:
- “Personal data” (Art. 4 No. 1 DSGVO) means any information relating to an identified or identifiable natural person (“data subject”). A person is identifiable if (s)he can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, an online identifier, location data, or by means of information relating to his or her physical, physiological, genetic, mental, economic, cultural or social identity characteristics. The identifiability can also be given by means of a linking of such information or other additional knowledge. The origin, form, or embodiment of the information is irrelevant (photographs, video or audio recordings may also contain personal data).
- “Processing” (Art. 4 No. 2 GDPR) means any operation which involves the handling of personal data, whether or not by automated (i.e., technology-based) means. This includes, in particular, the collection (i.e., acquisition), recording, organization, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment, combination, restriction, erasure or destruction of personal data, as well as the change of a purpose or intended purpose on which a data processing was originally based.
- “Controller” (Art. 4 No. 7 GDPR) means the natural or legal person, public authority, agency, or other body which alone or jointly with others determines the purposes and means of the processing of personal data.
- “Third party” (Art. 4 No. 10 GDPR) means any natural or legal person, public authority, agency, or other body other than the data subject, the controller, the processor, and the persons who, under the direct authority of the controller or processor, are authorized to process the personal data; this also includes other group-affiliated legal entities.
- “Processor” (Art. 4 No. 8 GDPR) is a natural or legal person, authority, institution, or other body that processes personal data on behalf of the controller, in particular in accordance with the controller’s instructions (e.g., IT service provider). In the sense of data protection law, a processor is in particular not a third party.
- “Consent” (Art. 4 No. 11 GDPR) of the data subject means any freely given, specific, informed, and unambiguous indication of his or her wishes in the form of a statement or other unambiguous affirmative act by which the data subject signifies his or her agreement to the processing of personal data relating to him or her.
(2) Name and address of the data controller
The controller of your personal data within the meaning of Art. 4 No. 7 DSGVO is us:
de Vries/Mandler/Mathews GbR
Telephone: +49 151 178 324 79
E-mail address: email@example.com
(3) Legal basis for data processing
In principle, any processing of personal data is prohibited by law and only permitted if the data processing falls under one of the following justifications:
- Art. 6 para. 1 p. 1 lit. a DSGVO (“consent”): Where the data subject has voluntarily, in an informed manner, and unambiguously indicated by a statement or other unambiguous, affirmative act that (s)he consents to the processing of personal data relating to him or her for one or more specific purposes;
- Art. 6 para. 1 p. 1 lit. b DSGVO: If the processing is necessary for the performance of a contract to which the data subject is a party or for the performance of pre-contractual measures taken at the data subject’s request;
- Art. 6 para. 1 sentence 1 lit. c DSGVO: If processing is necessary for compliance with a legal obligation to which the controller is subject (e.g., a legal obligation to keep records);
- Art. 6 para. 1 p. 1 lit. d DSGVO: If the processing is necessary to protect vital interests of the data subject or another natural person;
- Art. 6 para. 1 p. 1 lit. e DSGVO: If the processing is necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in the controller; or
- Art. 6 para. 1 p. 1 lit. f DSGVO (“Legitimate Interests”): If the processing is necessary to protect legitimate (in particular legal or economic) interests of the controller or a third party, unless the conflicting interests or rights of the data subject override (in particular, if the data subject is a minor).
For the processing operations we carry out, we indicate the applicable legal basis in each case below. A processing operation may also be based on several legal bases.
(4) Data erasure and storage period
Your data will only be processed for as long as is necessary to achieve the respective processing purposes; the legal bases stated in the context of the processing purposes apply accordingly. If no explicit storage period is specified below, your personal data will be deleted or blocked as soon as the purpose or legal basis for the storage no longer applies.
The storage period may also include the periods of the initiation of a contract (pre-contractual legal relationship) and the processing of a contract. On this basis, personal data is regularly deleted within the framework of the fulfillment of our contractual and/or legal obligations unless its temporary further processing is necessary for the following purposes:
- Fulfillment of legal obligations to retain data, which result, for example, from the German Commercial Code (§§ 238, 257 para. 4 HGB) and the German Fiscal Code (§ 147 para. 3, 4 AO). The periods specified there for retention or documentation are up to ten years;
- preservation of evidence, taking into account the statute of limitations. According to §§ 194 ff. of the German Civil Code (BGB), these limitation periods can be up to 30 years, with the regular limitation period being three years.
(5) Data security
We use appropriate technical and organizational security measures to protect your data against accidental or intentional manipulation, partial or complete loss, destruction, or unauthorized access by third parties (e.g., SSL encryption for our website). Our security measures are continuously improved in line with technological developments.
(6) Cooperation with processors
Like many other companies, we sometimes use external service providers to process our business transactions. If and to the extent that we cooperate with processors, they will only act on our instructions. In addition, the processors within the meaning of Art. 28 DSGVO have been contractually obligated to comply with the applicable data protection provisions.
(7) Conditions for the transfer of personal data to third countries
Within the scope of our business relationships, your personal data may be passed on or disclosed to third-party companies. These may also be located outside the European Economic Area (EEA), i.e., in third countries. Such processing takes place exclusively to fulfill contractual and business obligations and maintain your business relationship with us. We will inform you about the respective details of the transfer in the relevant places below.
The European Commission certifies data protection comparable to the EEA standard in some third countries through so-called adequacy decisions (a list of these countries and a copy of the adequacy decisions is available here: http://ec.europa.eu/justice/data-protection/international-transfers/adequacy/index_en.html). However, in other third countries to which personal data may be transferred, there may not be a consistently high level of data protection due to a lack of legal provisions. If this is the case, we ensure that data protection is sufficiently guaranteed. This is possible through binding company regulations, standard contractual clauses of the European Commission for the protection of personal data, certificates, or recognized codes of conduct.
(8) No automated decision-making (including profiling)
We do not intend to use any personal data collected from you for any automated decision-making process (including profiling).
(9) No obligation to provide personal data
We do not make the conclusion of contracts with us dependent on you providing us with personal data beforehand. As a customer, you are under no legal or contractual obligation to provide us with your personal data; however, we may only be able to provide our services to a limited extent or not at all if you do not provide us with the necessary data. If this should exceptionally be the case in the context of the products offered by us presented below, you will be informed of this separately.
(10) Legal obligation to transmit certain data
Under certain circumstances, we may be subject to a special statutory or legal obligation to make the lawfully processed personal data available to third parties, in particular public bodies (Art. 6 para. 1 sentence 1 lit. c DSGVO).
(11) Your rights
You can exercise your rights as a data subject regarding your processed personal data at any time by contacting us using the contact details provided at the beginning of A.(2). As a data subject, you have the right
- to request information about your data processed by us in accordance with Art. 15 DSGVO. In particular, you can request information about the processing purposes, the category of data, the categories of recipients to whom your data has been or will be disclosed, the planned storage period, the existence of a right to rectification, erasure, restriction of processing or objection, the existence of a right of complaint, the origin of your data if it has not been collected by us, as well as the existence of automated decision-making including profiling and, if applicable, meaningful information about its details;
- in accordance with Art. 16 DSGVO, to demand the correction of incorrect data or the completion of your data stored by us without delay;
- in accordance with Art. 17 DSGVO, to request the deletion of your data stored by us, unless the processing is necessary for the exercise of the right to freedom of expression and information, for compliance with a legal obligation, for reasons of public interest or for the assertion, exercise, or defense of legal claims;
- in accordance with Art. 18 DSGVO, to request the restriction of the processing of your data, insofar as the accuracy of the data is disputed by you or the processing is unlawful;
- pursuant to Art. 20 DSGVO, to receive the data that you have provided to us in a structured, common, and machine-readable format or to request the transfer to another controller (“data portability”);
- object to the processing in accordance with Art. 21 DSGVO, provided that the processing is based on Art. 6 (1) p. 1 lit. e or lit. f DSGVO. This is particularly the case if the processing is not necessary to fulfill a contract with you. Unless it is an objection to direct marketing, when exercising such an objection, we ask you to explain the reasons why we should not process your data as we have done. In the event of your justified objection, we will review the situation and either discontinue or adjust the data processing or show you our compelling legitimate grounds on the basis of which we will continue the processing;
- revoke your consent at any time in accordance with Art. 7 (3) DSGVO, if you have given such consent. This has the consequence that we may no longer continue the data processing based on this consent in the future; and
- complain to a data protection supervisory authority about the processing of your personal data in our company in accordance with Art. 77 DSGVO, for example, to the data protection supervisory authority responsible for us: The Hamburg Commissioner for Data Protection and Freedom of Information, Ludwig-Erhard-Str. 22, 20459 Hamburg, e-mail: firstname.lastname@example.org.
(12) Changes to the data protection information
In the context of the further development of data protection law as well as technological or organizational changes, our data protection information is regularly checked for the need to adapt or supplement it. You will be informed of any changes in particular on our website at https://ryddle.games/en/dataprivacy/. This data protection notice is current as of July 2022.
II. Visiting our website
(1) General information
You can obtain information about our company and the services we offer in particular at https://www.ryddle.games/ together with the associated sub-pages (hereinafter, collectively referred to as the “website”). When you visit our website, your personal data may be processed.
(2) Processed personal data
When using the website for information purposes, the following categories of personal data are collected, stored, and processed by us:
“log data”: When you visit our websites, a so-called protocol data record (so-called server log files) is stored temporarily and anonymously on our web server. This consists of:
- the page from which the website was requested (so-called referrer URL)
- the name and URL of the requested page
- the date and time of the request
- the description of the type, language, and version of the web browser used
- the IP address of the requesting computer, which is shortened so that a personal reference can no longer be established
- the amount of data transferred
- the operating system
- the message whether the request was successful (access status/ttp status code)
- the GMT time zone difference
“Contact form data”: When contact forms are used, the data transmitted through them are processed (surname and first name, e-mail address, and the time of transmission).
(3) Purpose and legal basis of data processing
We process the personal data described in more detail above in accordance with the provisions of the GDPR, the other relevant data protection regulations and only to the extent necessary. Insofar as the processing of personal data is based on Art. 6 (1) sentence 1 lit. f DSGVO, the aforementioned purposes also represent our legitimate interests.
The processing of log data serves statistical purposes and to improve the quality of our website, in particular the stability and security of the connection (legal basis is Art. 6 para. 1 p. 1 lit. f DSGVO).
Contact form data is processed for the purpose of handling customer inquiries. The legal basis for this is Art. 6 para. 1 p. 1 lit. f DSGVO. If your use of the contact form aims at the conclusion of a contract, the additional legal basis for the processing is Art. 6 para. 1 lit. b DSGVO.
(4) Transfer of personal data to third parties; justification basis
The following categories of recipients may have access to your personal data:
- Service providers for the operation of our website and our services and for the processing of data stored or transmitted by the systems (e.g., for hosting services or payment processing). The legal basis for the transfer is Art. 6 para. 1 p. 1 lit. b as well as Art. 6 para. 1 p. 1 lit. f DSGVO;
- Government agencies/authorities, insofar as this is necessary to fulfill a legal obligation. The legal basis for the disclosure is then Art. 6 para. 1 p. 1 lit. c DSGVO;
- Persons employed to carry out our business operations (e.g., auditors, banks, insurance companies, legal advisors, parties involved in company acquisitions or the establishment of joint ventures). The legal basis for the disclosure is then Art. 6 para. 1 sentence 1 lit. b, or lit. f DSGVO.
For guarantees of an appropriate level of data protection in the event of data being passed on to third countries, see I.(7).
We will only pass on your personal data to third parties beyond the scope described above if you have given your express consent in accordance with Art. 6 (1) sentence 1 lit. a DSGVO.
Cookies can contain data that make it possible to recognize the device used. In some cases, however, cookies only contain information on certain settings that cannot be related to a specific person. However, cookies cannot directly identify a user.
A distinction is made between session cookies, which are deleted as soon as you close your browser, and permanent cookies, which are stored beyond the individual session. With regard to their function, a distinction is made between cookies:
- Technical cookies: these are essential to navigate the website, use basic functions and ensure the security of the website; they do not collect information about you for marketing purposes nor do they store which web pages you have visited;
- Performance cookies: these collect information about how you use our website, which pages you visit and, for example, whether errors occur during website use; they do not collect information that could identify you – all information collected is anonymous and is only used to improve our website and find out what interests our users;
- Advertising cookies, targeting cookies: these are used to provide the website user with tailored advertising on the website or third party offers and to measure the effectiveness of these offers; advertising and targeting cookies are stored for a maximum of 13 months;
- Sharing cookies: these are used to improve the interactivity of our website with other services (e.g., social networks); sharing cookies are stored for a maximum of 13 months.
b) Analysis services
For the purpose of demand-oriented design and continuous optimization of our website, we use Google Analytics, a web analysis service provided by Google LLC (1600 Amphitheatre Parkway, Mountain View, CA 94043, USA; hereinafter “Google”). In this context, pseudonymized usage profiles are created, and cookies are used. The information generated by the cookie about your use of this website, such as
- Browser type/version,
- operating system used,
- Referrer URL (the previously visited page),
- host name of the accessing computer (IP address),
- time of the server request,
will be transmitted to and stored by Google on servers in the United States. The information is used to evaluate the website’s use, compile reports on website activity and provide other services related to website and internet use for the purposes of market research and demand-oriented design of this website. This information may also be transferred to third parties if this is required by law or if third parties process this data on our behalf. Under no circumstances will your IP address be merged with other Google data. The IP addresses are anonymized so that an allocation is not possible (IP masking).
You can also prevent the collection of data generated by the cookie and related to your use of the website (including your IP address) and the processing of this data by Google by downloading and installing a browser add-on.
As an alternative to the browser add-on, especially for browsers on mobile devices, you can also prevent the collection by Google Analytics by clicking on this link. An opt-out cookie will be set, which prevents the future collection of your data when visiting this website. The opt-out cookie is only valid in this browser and only for this website and is stored on your device. If you delete the cookies in this browser, you must set the opt-out cookie again.
Further information on data protection in connection with Google Analytics can be found in the “Google Analytics Help.”
c) Social media sites
We have various presences on so-called social media platforms:
Address: Meta Platforms Ireland Limited, 4 Grand Canal Square, Dublin 2, Ireland
Our presence: https://facebook.com/ryddleadventures
Information on data protection: https://de-de.facebook.com/policy.php
Address: Meta Platforms Ireland Limited, 4 Grand Canal Square, Dublin 2, Ireland
Our presence: https://instagram.com/ryddleadventures
Privacy information: https://help.instagram.com/519522125107875/?helpref=uf_share
Address: Twitter International Company, One Cumberland Place, Fenian Street, Dublin 2, D02 AX07, Ireland
Our presence: https://twitter.com/ryddleadventure
Information on data protection: https://twitter.com/de/privacy
We use the technical platform and services of the providers for these information services. We would like to point out that you use our appearances on social media platforms and their functions on your own responsibility. This applies in particular to the use of interactive functions (e.g., commenting, sharing, rating). When you visit our websites, the providers of the social media platforms collect, among other things, your IP address, and other information that is stored in the form of cookies on your end device. This information is used to provide us, as the operator of the accounts, with statistical information about the interaction with us.
The data processing may differ depending on whether you are registered and logged in to the social network or visit the site as a non-registered and/or non-logged-in user. When you access a post or the account, the IP address assigned to your terminal device is transmitted to the provider of the social media platform. If you are currently logged in as a user, a cookie on your end device can be used to track how you have moved around the network. Buttons embedded in websites enable the platforms to record your visits to these website pages and assign them to your respective profile. This data can be used to offer content or advertising tailored to you. If you want to avoid this, you should log out or deactivate the “stay logged in” function, delete the cookies on your device and restart your browser.
To exercise your data protection rights, you can contact us or the respective social media platform provider. If one party is not responsible for responding or needs to receive the information from the other party, we or the provider will then forward your request to the respective partner. Please contact the operator of the social media platform directly for questions about the profiling and processing of your data when using the website. For questions about the processing of your interaction with us on our site, write to the contact details we have provided above.
The providers describe what information the social media platform receives and how it is used in their data protection statements (see link in the table above). There you will also find information on contact options as well as on the setting options for advertisements.
III. ryddle Walking tour
(1) Data processing in the context of processing your order
When you book a walking tour or buy a voucher at ryddle, we collect your order data. Order data may include the following information depending on the type of sale and processing status:
- Order number
- Order date
- Name of the walking tour booked
- Payment method details
- Delivery and billing addresses
- Your e-mail address
- Messages and communication related to the booked walking tour
- Delivery and payment status, e.g. “Completed” or “Dispatched
The legal basis for the above-mentioned processing is in each case Art. 6 Para. 1 S.1 lit. b DSGVO.
(2) Data processing for payment
ryddle offers various payment options, such as payment by credit card, payment by PayPal, and payment by Sofortüberweisung. For the purpose of payment processing, depending on which payment method is used, various payment data (name; e-mail address; country; IP; order number; date; price; payment status; validity of the start code; billing address) may be collected. If you pay for the booking of a walking tour via one of the payment service providers offered, the respective payment service providers are generally responsible for the processing of the payment information in terms of data protection law:
- Concept Den Limited (SendOwl), 107 Cheapside, 9th Floor, London EC2V 6DN, UK.
Information on data protection: https://www.sendowl.com/privacy
- Stripe Inc., 354 Oyster Point Blvd, South San Francisco, CA 94080, USA
Informationen zum Datenschutz: https://stripe.com/de/privacy
- PayPal (Europe) S.à r.l. et Cie, S.C.A., 22-24 Boulevard Royal, 2449 Luxembourg, Luxembourg
Information on data protection: https://www.paypal.com/us/webapps/mpp/ua/privacy-full
- paydirekt GmbH (giropay), Stephanstraße 14-16, 60313 Frankfurt am Main, Germany
Information on data protection: https://www.giropay.de/rechtliches/datenschutzerklaerung
The legal basis for the above processing is in each case Article 6 (1) sentence 1 lit. b DSGVO and Article 6 (1) lit. f DSGVO.
(3) Data processing in connection with the implementation of the walking tour
a) User ID and mobile phone number for identification purposes
When the walking tour is started via WhatsApp Messenger, a user ID is automatically generated. This user ID also contains the mobile phone number of the device on which the walking tour was started. The user ID is used exclusively to assign a player for our internal administrative purposes.
The legal basis for this is Art. 6 para. 1 sentence 1 lit. b DSGVO and Art. 6 para. 1 sentence 1 lit. f DSGVO.
b) Photo memory of your personal walking tour
In the context of the walking tours, you or your group will be asked to send photos (“selfies”). Sending a selfie is voluntary and not required for progressing in the game. You can refuse to take and send a selfie by sending a negative text message (“No”) or by using the “Skip” function. We will also point this out to you explicitly during the game.
If you would like to take and transmit a selfie of yourself alone or of you and your group, we will consider the transmission of your selfie as the consent of all persons recognizable on the selfie according to Art. 6 para. 1 lit. a DSGVO. You can revoke your consent at any time with effect for the future. To do so, simply send a corresponding message to email@example.com.
The selfies submitted will be used exclusively for the creation of an individual photo collage, which will be made available for you to download in the chat later in the game. We will never pass on your selfie to third parties or use it for our own (advertising) purposes without your explicit consent.
For the purpose of the automatic creation of the photo collage, your provided photos will be temporarily stored on a server of our hosting provider. The photos will be automatically deleted from the server once a week.
c) Receiving hints by phone call
In some cases, you may be asked to enter your mobile phone number during the course of the game in order to receive a hint (played from a tape) on how to complete the rally by phone. If you want to listen to the message and provide your mobile phone number for this purpose, we will consider this as consent pursuant to Art. 6 Para. 1 lit. a DSGVO. You can revoke your consent at any time with effect for the future. Simply send us a message to this effect to firstname.lastname@example.org. In addition, data processing is carried out on the basis of Art. 6 para. 1 p. 1 lit. f.
If you do not want to give your mobile phone number to receive the hint, you can reject this by means of a negating text message (“No”) or the “Skip” function. We will also point this out to you separately in the course of the game.
Your mobile phone number will only be used for the hint call. No further processing will take place. However, we would like to point out that your mobile phone number may be processed for other purposes and on the basis of other legal grounds, see III.(3).(a).
Status of the information on data protection: July 2022