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Promotion Software GmbH Privacy Policy

Promotion Software GmbH is serious about protecting users personal data and is obliged to adhere
to all valid, related laws, including Directive 94/46/EG of the European Parliament and Council
from October 25, 1995 for the protection of individuals when processing personal data and to the
free flow of data as well as other appropriate, applicable laws and legal regulations in your country
of residence.
We have employed technical and organizational measures which, in our opinion, ensure that data
protection laws are observed by us as well as by external service providers working for us.

Personal data
Personal data are individual details about personal or business relationships of a specific or
ascertainable person. The data includes information which is related or applicable to an individual
person or creates a connection to that person. This includes information such as name, address,
mailing address, and phone number. Information that cannot be associated with an actual identity
(e.g., favourite websites or number of site users) is not protected.
In principle, you are entitled to use portions of our online services (website) without disclosing your
identity. If, however, you would like to participate in games and the portal, we request the following
personal data:
E-mail address
The following data is requested for competitions and other events:
- Name
- Mailing address
- Possibly phone number
Additional data such as age and hobbies may be requested, within the framework of other actions
(e.g., "Player of the Month"), and , published, with your permission, on the Web or in printed
Promotion Software GmbH employees are not authorized to request additional user data, such as
credit card information, banking information, passwords, or phone numbers. Divulging personal
information in online chat is the sole responsibility of users.

Storage of security of personal data

Data collected by us during player account registration is stored on the operators server database
(e-mail address). [Address: Promotion Software GmbH, Karlstrasse 3, 72072 Tuebingen, Germany]
Persons who require access because of technical, business, or editorial maintenance of the server
and portal are legally bound by an agreement of confidentiality and non-disclosure.
A copy of the data is made available to us via FTP and stored on a local PC.
Your e-mail/mailing addresses may be requested via e-mail by support and stored with us.
We are committed to data security within the framework of applicable data protection laws. Please
note however that no electronic communications are totally secure. We remind you that, despite our
high standards, information that you voluntarily provide on the Web are never guaranteed to be
100% secure. There is always the potential danger that third persons may obtain unauthorized

access. Promotion Software GmbH is not responsible or liable for the disclosure of information due
to data transmission errors and/or unauthorized access by third parties.

Data processing
Once you have completed a declaration of consent, we collect, store, and process personal
information for the purpose of individual information and management (e.g., newsletters).
We use e-mail addresses for administrative purposes such as account activation information,
welcome e-mails, and newsletter distribution. Users may opt out of newsletters at any time.
If a user modifies account information (password, account name) or is temporarily or permanently
blocked from the service ("kick, ban"), the system automatically sends an e-mail to the previously
provided address. We do not control the distribution of such e-mails. This can only be achieved by
deleting all account-related data.
For security purposes, data that could be used for identification (e.g., IP address, date, and time) is
stored on our servers when you are granted access. Personal data is not used for any other purposes,
apart from legal or official requirements. We reserve the right to conduct statistical analysis of
anonymous data sets.

Sharing of personal information with third

Your personal data will not be shared with third parties without your express consent. If data is
shared with service providers as part of contractual data processing, they are required to conform to
the BDSG (Federal Data Protection Act) and other legal requirements as well as to Promotion
Software GmbH Privacy Policy. We must provide data to authorized authorities in accordance with
legal or judicial decrees.
Storing, modifying, or using data for other purposes is permitted only when necessary to protect
against serious disadvantages for the common welfare, danger to public security, or protecting the
interests of the common welfare or when required for the prosecution of criminal or regulatory
violations, the enforcement or execution of penalties or sanctions in accordance with 11 Paragraph
1 No. 8 of the criminal code, correctional actions in accordance with juvenile law, or enforcement
of civil penalties.
Promotion Software GmbH employs appropriate measures to prevent the sharing of user personal
data, including user account data, with third parties, except under the following conditions:
(1) To recoup costs associated with use of service.
(2) To generate statistics for academic or marketing research on an anonymous basis
(3) For the enforcement of certain guidelines of applicable laws and regulations, which expressly
authorize such sharing, or to comply with judicial decrees that mandate such sharing.
(4) Upon catastrophic events, emergencies, or other acts of nature that are beyond the control of
Promotion Software GmbH.
Anyone may access (view) contributions placed in the discussion forum. You should ensure, before
publishing, that your contributions do not contain information that is not appropriate for public
viewing. You should be aware that your contributions may be accessed by search engines and
accessible worldwide without specifically targeting our portal. Deleting or correcting such entries is
frequently not possible with foreign operators.

Non-liability for online partner services

We remind you that in various technical areas we work with external partners who also offer
Internet sites and services accessible from our sites. These partners generally have their own data
protection guidelines. We assume no responsibility or liability for such declarations or activities that
take place at other sites.

Right of withdrawal
You may delete data that you have entrusted with us at any time. Please send an e-mail requesting
deletion of your account data to We remind you that the
remonstrance of certain data for certain periods of time is stipulated by commercial and taxation
laws. These data may only be deleted following legally stipulated time periods.

Modification of the Privacy Policy

Promotion Software GmbH reserves the right to modify the Privacy Policy at any time in
accordance with applicable privacy policies. Such modifications may take place without express,
written notice to users. Current regulations may be reviewed any time at Please visit this page frequently.

Participation in contests and its procedure

governed by the following provisions.
1 Contest
To take part in the contest, participants must follow the instructions provided in the contest
description. The electronically recorded receipt of the email by Promotion Software GmbH is used
to determine whether the deadline has been met. The deadline ends on the given date of the contest.

2 Participants
(1) Participants must be at least 18 years old. Participants, who are younger than 18 years old, must
seek consent from their legal guardian prior to participation.
(2) To participate in the contest, all information provided must be true.

3 Exclusion from the contest

(1) Employees of Promotion Software GmbH and their relatives are excluded from participation.
(2) In the event of a breach of these terms and conditions of participation, Promotion Software
GmbH reserves the right to exclude individuals from taking part in the contest.
(3) Individuals who, by the use of prohibited means or other manipulations, gain an advantage will
also be excluded. In these cases, prizes may also be revoked and recalled if necessary.

4 Contest procedure
(1) Promotion Software GmbH is responsible for conducting the contest and selecting the prizes.

(2) Promotion Software GmbH will contact the participants by email when the contest has ended. In
the event of a win, it is necessary for participant to provide their mailing address to Promotion
Software GmbH within 14 days. The prize claim will lapse if participants have not contacted
Promotion Software GmbH within 14 days and provided their mailing address; in this case, the
prize will drawn again. A claim to the prize will cease to exist upon expiry of this deadline.
(3) Promotion Software GmbH shall determine the terms of delivery that will apply to the delivery
of the prizes. If the delivery of the prize is impossible or is only possible under unreasonable
circumstances, the winners will receive a replacement prize of the same value.
(4) Promotion Software GmbH will inform the winners in writing (via email) and, where
appropriate, publish their names on or on website of Promotion
Software GmbH products. The winners herewith declare their express consent to this form of
(5) Each participant is only eligible to submit a number of entries as described in contest-specific
rules. Prizes will be awarded according to the contest rules.
(6) The payment of a cash equivalent for the prizes is excluded. Prize claims are not transferable.
(7) Complaints are to be lodged with Promotion Software GmbH in writing, stating the name of the
contest, within 14 days after becoming aware of the cause for such complaint. Complaints that are
lodged by telephone or late cannot be processed.

5 Premature termination of the contest

(1) Promotion Software GmbH reserves the right to cancel or terminate the contest at any time
without prior notice. Promotion Software GmbH will exercise this right, in particular if the proper
conduct of the contest cannot be ensured due to technical reasons (e.g., computer viruses,
manipulation, or errors in the hardware and/or software) or legal reasons. Inasmuch as such a
termination is caused by the behavior of a participant, Promotion Software GmbH may claim
compensation from that participant for the damage caused.

6 Data protection
(1) To participate in the contest, it is sufficient to send in a valid email address. At the end of the
contest, the participants will be contacted by Promotion Software GmbH via the email address
provided. In the event of a win, Promotion Software GmbH will request the participant to send a
mailing address to which the corresponding prize can be sent and (for age-sensitive prizes) a copy
of their identity card. All data will be collected by Promotion Software GmbH exclusively within
the scope of this contest and saved only for the duration thereof.
(2) Promotion Software GmbH is obligated to adhere to data protection and media law with respect
to the data participants provide. In particular, the data will be kept confidential.

7 Liability
(1) Upon handing over the prize, Promotion Software GmbH is released from all obligations.
Promotion Software GmbH assumes no liability for legal and/or material defects.
(2) Claims related to the prizes received are to be directed directly to the manufacturer/provider
within the scope of product liability or other liability.
(3) No responsibility is taken for the announcement of the winner.
(4) Promotion Software GmbH is not liable for damages caused by fire, delays or interruptions in
the transmission, disruptions in technical equipment and services, incorrect content, loss or deletion
of data, viruses, or other reasons that can occur when participating in contests, unless such damages
were caused deliberately or gross negligently by Promotion Software GmbH (its executives bodies,
employees, or agents).
(5) Liability is excluded for the persons excluded by 3.

8 Miscellaneous
(1) All decisions are final.
(2) These terms and conditions of participation and the entire legal relationship between the
participants and Promotion Software GmbH is exclusively subject to the laws of the Federal
Republic of Germany.
(3) Inasmuch as individual provisions of the terms and conditions of participation are or become
invalid, the validity of the other provisions shall remain unaffected.
(4) These terms and conditions of participation may be amended by Promotion Software GmbH at
any time without separate notice.

Questions and comments

For questions, concerns, or comments on the topic of data protection, please contact Promotion
Software GmbH data protection representative Michael Monger (