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Privacy Policy – Pink Frog Games GmbH (“PNKFRG”)

The protection of personal data is our highest priority. At this point we inform you about which personal data we collect on our website 
and how we deal with them.

1. Responsible body, Scope of Application
The responsible body 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 the:
Pink Frog Games GmbH
Besselstr. 14, 10969 Berlin, Germany
Executive Directors:
Philip Lanik
Tanja Turunen
(hereinafter referred to as ‘Service Provider’).

The browser can be adapted to the use of our website at the beginning of the website’s visit to the personally desired data collection level.

As part of the services offered through our platforms, we collect and use personal information. In addition, we create analyzes for statistical and market analysis purposes in anonymous form.


Personal data is being recorded in the technically necessary amount only. In no case will we sell the data collected or pass it on to third parties for any other reason without your prior consent. The following statement gives you an overview of how we ensure this protection and what kind of data is collected for which purpose.

2. Legal bases
Regarding Art. 4 of the GDPR personal data is defined as any information relating to an identified or identifiable natural person ('the Data Subject'); a natural person is regarded as identifiable, which can be identified directly or indirectly, in particular by association with an identifier such as a name, an identification number, location data, an online identifier or one or more special features, the expression of the physical, physiological, genetic, mental, economic, cultural or social identity of this natural person.


Insofar as we obtain the consent of the data subject for processing of personal data, Art. 6 para. 1 lit. a) GDPR as legal basis. In the processing of personal data required to fulfill a contract of which the data subject is a party, Art. 6 para. 1 lit. b) GDPR as legal basis. This also applies to processing operations required to carry out pre-contractual measures.

In the event that vital interests of the data subject or another natural person require the processing of personal data, Art. 6 (1) lit. d) GDPR as legal basis.

If processing is necessary to safeguard the legitimate interests of our company or a third party, and if the interests, fundamental rights and freedoms of the data subject do not prevail over the first interest, Art. 6 para. 1 lit. f) GDPR as legal basis for processing.

Already at this point we point out that all data will be deleted by us as soon as they are no longer necessary for the achievement of the respective purpose of their survey. This is subject to such data, the storage of which is required by law.

In the context of data processing that is not carried out by us, we only work with companies that have either adapted their data processing to the provisions of the GDPR or are subject to a comparable level of data protection under agreements such as the EU-US Privacy Shield.

In the following we would like to describe our usage of the data you provide. 

3. Data collection and use in general on our website
Already when visiting our website usage-related data about your use process arise with us. However, we do not associate this information with you. The purpose of the data collection is solely to continuously improve the quality of our services and to further develop them, for which we create anonymous user behavior analyzes. After completion of your visit with us we store your IP address only in anonymous form. For more details on the systems used, see the sections below on cookies and data collection in particular.

4. Cookies
In order to make the visit of our website attractive and to allow the use of certain functions, we can use so-called cookies on various pages. These are small text files that are stored on your device. Some of the cookies we use are deleted after the end of the browser session, i.e. after closing your browser (so-called session cookies).

4.1 Google Analytics 
We work with Google Analytics. This is a web analytics service provided by Google Inc. (1600 Amphitheater Parkway, Mountain View, CA 94043, USA; "Google"). IP anonymization has been activated on our websites, so that the IP address of the users of Google is shortened and thus anonymized within member states of the European Union or in other contracting states of the Agreement on the European Economic Area. Then, the anonymized information about your use of our website generated by the Google Analytics cookie is usually transmitted to a Google server in the USA and stored there. Google will use this information on our behalf to evaluate your use of the website, to compile reports on website activity, and to provide us with other services related to website activity and internet usage. The IP address provided by Google Analytics as part of Google Analytics will not be merged with other Google information.

You can prevent the collection by Google of the data generated by the cookie and related to your use of the website (including your IP address) as well as the processing of this data by installing the browser plug-in available under the following link:

For more information about the Google Analytics Terms of Use and Privacy, please visit or

5. Data collection in particular, data processing
5.1 Contact via e-mail and contact form
On our website, it is possible to contact us for information about us or our product.
If a user realizes this option, the data entered in the input mask or the e-mail will be transmitted to us and saved. These data are according to the request of the user

  • first name

  • last name

  • e-mail address

  • personal data if provided within the message 

At the time of sending the message, the following data is also stored

  • IP address, shortened (anonymized), broad IP-based location information 

  • Date and time of registration

Depending on the processing, consent is obtained for processing the data and reference is made to our privacy policy. In this regard, we refer to point three of our privacy policy.

All data collected in this context will be deleted by us immediately, as soon as they are no longer necessary for the achievement of the respective purpose of their survey. This is subject to such data, the storage of which is required by law.

5.2 Data Processing on our Social Media Pages; Nature and purpose of data processing:
We operate pages on the following social media channels:

  • Facebook: or mobile app by Facebook Inc., 1601 S. California Ave, Palo Alto, CA 94304, USA or Facebook Ireland Ltd., 4 Grand Canal Square, Dublin 2, Ireland, please refer to:

  • Twitter: or mobile app by Twitter Inc., 1355 Market Street, Suite 900, San Francisco, CA 94103, USA, please also refer to:,

  • LinkedIn: or mobile app by LinkedIn Corporation, Legal Department – Privacy, 1000 W. Maude Ave, Sunnyvale, CA 94085, USA or LinkedIn Ireland Unlimited Company, Wilton Plaza, Wilton Place, Dublin 2, Ireland, please refer to:

  • Instagram: or mobile app by Instagram by Facebook Inc., 1601 S. California Ave, Palo Alto, CA 94304, USA or Facebook Ireland Ltd., 4 Grand Canal Square, Dublin 2, Ireland, please refer to:

When you visit our social media pages, data is processed both by us and by the responsible social media provider as the responsible party.

The respective provider of social media assumes the data protection obligations towards you as the user, such as information on data processing, and is the contact person for your rights. This follows from the fact that such a provider has direct access to the relevant information on the social media page and the processing of your data. On our social media pages, we can communicate with you and provide you with interesting information. We may receive further data from you through your comments, shared images, messages, and reactions, which we then process to communicate with you. If you use social media on several end devices, a cross-device analysis of the data can take place. Furthermore, the providers of social media pages may also use cookies and tracking technologies to analyze and improve their services.

5.3 Legal basis:
Data processing takes place with your consent or for the purpose of answering your inquiry (Art. 6 (1) a, b GDPR) or on the basis of legitimate interests in improving the services and presentation to the outside world (Art. 6 (1) f GDPR).

5.4 Recipients:
The recipients are the service providers mentioned above which may act as joint controllers with us for the provision of certain services. For Facebook see the agreement at:

6. How we use your information
The main reason we use your information is to deliver and improve our services. Additionally, we use your information to help keep you safe. 

6.1 Account administration 

  • Create and manage your account

  • Provide you with customer support and respond to your requests

  • Communicate with you about our services

6.2 Service improvement 

  • Administer focus groups and surveys

  • Conduct research and analysis of users’ behavior to improve our services and content (for instance, we may decide to change the look and feel or even substantially modify a given feature based on users’ behavior)

  • Develop new features and services (for example, we may decide to build a new interests-based feature further to requests received from users).

6.3 Prevention and detection of fraud or other illegal or unauthorized activities

  • Address ongoing or alleged misbehavior on and off-platform

  • Perform data analysis to better understand and design countermeasures against these activities

  • Retain data related to fraudulent activities to prevent against recurrences

6.4 Ensuring legal compliance

  • Comply with legal requirements

  • Assist law enforcement

  • Enforce or exercise our rights, for example our Terms

7. Affected rights
If personal data are processed by you, you are "affected person" and you have the following rights towards us as responsible persons:

7.1 Right to information
You have the right to receive a confirmation from us free of charge if we process personal data concerning you. If this is the case, then you have the right to information about this personal data and to other information that you can refer to Art. 15 GDPR. You can contact us by mail or e-mail.

7.2 Right to rectification
You have the right to demand immediate correction of incorrect personal data concerning you. You also have the right to request the completion of incomplete personal data, including by means of a supplementary statement, taking into account the above-mentioned purposes of processing. You can contact us by mail or email.

7.3 Right to cancellation
You have the right to demand the immediate deletion of personal data concerning you if one of the requirements of Art. 17 GDPR is fulfilled. You can contact us by mail or e-mail.

7.4 Right to restriction of processing
You have the right to demand that we restrict the processing if one of the requirements of Art. 18 GDPR is fulfilled. You can contact us by mail or e-mail.

7.5 Right to information
If you have the right of rectification, erasure or restriction of the processing to the controller, he / she is obliged to notify all recipients to whom the personal data concerning you have been corrected or deleted or processing restricted, unless: this proves to be impossible or involves a disproportionate effort.


You have a right to the person responsible to be informed about these recipients.

7.6 Data transferability
You have the right to receive the personal information that you have provided to us in a structured, common and machine-readable format and you have the right to transfer this data to another person without hindrance from us if the conditions of Art 20 DSGVO. You can contact us by mail or e-mail.

7.7 Right to object to processing for our legitimate interest
As far as we exceptionally process personal data on the basis of Art. 6 (1) (f) GDPR (i.e. for legitimate interests), you have the right to refuse to process your personal data at any time for reasons that arise from your particular situation to appeal to us. If we can not prove compelling legitimate reasons for further processing that outweigh your interests, rights and freedoms, or if we process the data from you for direct marketing purposes, then we will no longer process your data (see Art 21 DSGVO). You can contact us by mail or e-mail. As a contradiction in this sense is also a technical process that you use, for example, a unique technical information your web browser transmits us ("Do-Not-Track" message).

7.8 Right to object with granted consent
You have the right to revoke your consent to the collection and use of personal data with effect for the future at any time. You can contact us by mail or email. The lawfulness of the processing on the basis of the consent until the revocation is not affected.

7.9 Automated decision-making including profiling
You have the right not to be subjected to a decision based solely on automated processing - including profiling - that will have legal effect or similarly affect you in a similar manner. Unless the decision is required to conclude or fulfill a contract between you and us, it is permissible under Union or Member State legislation to which we are subject, and this legislation contains reasonable safeguards to safeguard your rights and freedoms and your legitimate interests or the decision is made with your expressed consent.


Such automated decision-making does not take place through us.

7.10 Voluntary provision of the data
If the provision of personal data is required by law or contract, we generally point this out when collecting the data. In some cases, the data we collect is required to conclude a contract, namely when we otherwise could not or could not sufficiently fulfill our contractual obligation to you. There is no obligation for you to provide personal information. However, the non-provision may result in the fact that we cannot perform or offer you a desired performance, action, measure or similar, or a contract with you is not possible.

If you would like to exercise one of the rights described above, you are welcome to contact us:
e-mail address:
Pink Frog Games GmbH
Executive Directors:
Philip Lanik
Tanja Turunen

7.11 Right to complain to a supervisory authority
You have the right, at any time and without prejudice to any other rights, to lodge a complaint with a data protection supervisory authority, in particular in the Member State of your residence, place of work or place of alleged infringement, if you believe that the processing of your personal data is contrary to data protection law contrary.
Privacy Policy, as of: April 2022
This Privacy Policy was created by ZK Law –​

Privacy notice of PopReel

I. Controller, Scope
PopReel is provided by Pink Frog Games GmbH Besselstrasse 14 10969 Berlin (hereinafter also referred to as “Provider”), acting as Controller in accordance with relevant data protection provisions. Please find full company and contact details in the relevant section of the PopReel-app.

We hereby inform you about which data we collect when, and how we process your personal data. This privacy notice describes the collection and processing of personal data when using the PopReel-app (hereinafter referred to as "App").

II. General information

1. Purposes of processing
In principle, we only process personal data of users as necessary to provide a functional App, our contents and to deliver our services. 

2. Legal basis for the processing of personal data
We mostly process personal data according to on one of the following legal bases:

  • Consent
    Whenever we collect the data subject’s consent to the processing of personal data, Art. 6 para. 1 a EU General Data Protection Regulation (GDPR) serves as the legal basis.

  • Contract or pre-contractual measures
    If the processing of personal data is necessary for the performance of a contract to which the data subject is party, Art. 6 para. 1 b GDPR serves as the legal basis. This also applies to processing operations that are necessary to carry out pre-contractual measures.

  • Legal obligation
    If the processing of personal data is necessary for compliance with a legal obligation which the Controller is subject to, Art. 6 para. 1 c GDPR serves as the legal basis.

  • Legitimate interests
    If processing is necessary for the purposes of the legitimate interests pursued by the Controller or a third party and if such interests are not overridden by the interests, fundamental rights and freedoms of the data subject, Art. 6 para. 1 f GDPR serves as the legal basis.


3. Data erasure and retention time

In principle and unless otherwise stated, your personal data will only be stored until the purpose of the collection and storage is achieved. If the storage is based on your consent, personal data can be stored as long as you do not revoke such consent.

Furthermore, data may be stored if it is required by European or national legal provisions, laws or regulations which we are subject to. Personal data will be blocked or deleted if the retention period set forth by the any such regulations expires, unless further storage is necessary for the conclusion or fulfilment of a contract.

4. Transfer to third countries

Unless otherwise stated, all data processing operations take place within the EU or the EEA countries. 


Data processing operations carried out by third-party providers established outside the mentioned geographical area may be carried out in part or in full in the countries the respective providers are based in, in accordance with the relevant and applicable data protection regulations.


A transfer of personal data outside the EU or the EEA shall only take place on the basis of on an adequacy decision of the European Commission or subject to appropriate safeguards, such as standard data protection clauses adopted by the European Commission.


A list of current adequacy decisions, as well as further information about the effect of the ECJ’s ruling in the case C-311/18 on Privacy Shield are available on the European Commission's App.

III. Personal data you provide voluntarily

Personal data processed when setting up an account
After installing the App on your mobile device, in order to use it you will have to register an account. When registering an account you will be asked to provide the following data: name / username / pseudonym, e-mail address, password, age. We need your name, e-mail and password in order to create an account that is solely connected to you and can uniquely be related to you. We need to collect information about your age in order to make sure that you’re an adult when using our services. 

The provision of the personal data mentioned above is a contractual requirement. Failure to provide them will result in unavailability of our service. 

The legal basis for processing is art. 6 par. 1 lit. b) GDPR.

Personal data uploaded to the service
When using our services, you may be given the option to upload, share, disseminate and/or otherwise make available content, as per the relevant provisions of our terms of service. When doing so, we will collect only personal data that you deliberately decide to share. The provision of personal data when sharing content is not required in order to use our service, nor is it a legal requirement. 

The legal basis for processing is therefore art. 6 par. 1 lit. a) GDPR.

Personal data processed when contacting us
If you submit a support request to us via the App, we will only collect such data and information that you will provide when describing the reason for your request. The provision of personal data is not required to this end. Should any personal data be provided, it will only be used to process your request and reply to it.
If you contact us via e-mail address specified on our App, you will provide the following personal data: name, e-mail address. This information will only be used to process your inquiry and reply to it. 

The legal basis for processing is therefore art. 6 par. 1 lit. b) GDPR.

V. Data Processors

In order to provide our services, we may cooperate with selected third-party providers who process data on our behalf (“Processors”). This applies for instance to hosting providers and payment service providers. As far as legally required, we have entered into agreements pursuant to art. 28 GDPR with Processors processing your personal data on our behalf.

VI. Processing in compliance with a legal obligation

Please note that, in addition to what specified in this privacy notice, your data may be processed in compliance with legal obligations which we are subject to. Please contact us in case you want to learn further details about such processing activities. 

In such cases the legal basis of the processing is art. 6 par. 1 lit. c) GDPR. 

X. Use of identifiers

1. Description and scope of data processing
In order to improve user experience of our App and to enable selected functions, we implement tracking technologies, allowing us and/or out partners to identify your device (hereinafter jointly referred to as “Identifiers”). Identifiers are usually small data sets being stored on or associated to your device. Some of the Identifiers we use expire after the end of the session, i.e. after you exit the App (session Identifiers). Other Identifiers remain on or associated to your device and enable us or our partner companies to recognise your device whenever you use the App (persistent Identifiers). 

You can set your device preferences in order to be notified about the use of Identifiers and decide individually about accepting or refusing them in certain cases or generally. 

Failure to agree to the use of Identifiers may result in limitations or in complete unavailability of our services.

2. Strictly necessary Identifiers
Some of the Identifiers we use are strictly necessary to allow us to deliver the service you requested or to operate our App. Some elements of our App require that your device be identified throughout the use of the App. Such technical Identifiers may collect personal information about you, such IP address, log-in information, App engagement data, App purchase data.

The processing of personal data through strictly necessary Identifiers – if any – is art. 6 par. 1 lit. f) GDPR. In case such Identifiers are necessary as a pre-contractual measure or for performing a contract with you, the legal basis is art. 6 par. 1 lit. b) GDPR. 

3. Other Identifiers
In addition, we use third-party Identifiers to monitor and evaluate user behaviour for statistics and market analysis purposes. Such Identifiers are provided by third parties and implemented in our App. Please refer to the following sections for details. Such Identifiers allow us to analyse your use of our service and improve it continuously. Analytics allow us to offer you a better service that meets your interests better. 

Unless otherwise specified, the legal basis of processing through other Identifiers mentioned below is your consent pursuant to art. 6 par. 1 lit. a) GDPR. Unless otherwise specified, the lifetime of Identifiers used based on your consent expires upon withdrawal of your consent. 

Google Analytics for Firebase or Firebase Analytics is an analytics service provided by Google Ireland Limited. To find out more about Google's use of data, consult Google's partner policy.
Firebase Analytics may share Data with other tools provided by Firebase, such as Crash Reporting, Authentication, Remote Config or Notifications. On our App we use Identifiers to run the Firebase Analytics service. You may opt-out of certain Firebase features through applicable device settings, such as the device advertising settings for mobile phones or by following the instructions in other Firebase related sections of this privacy policy, if available. Personal Data processed: Identifiers (Google Advertiser ID or IDFA, for example); Usage Data. 
Place of processing: Ireland – Privacy Policy.

This type of service has the purpose of hosting data and files that enable our App to run and be distributed as well as to provide a ready-made infrastructure to run specific features or parts of the App. Google BigQuery is service provided by Google Ireland Limited.

Personal Data processed: various types of Data as specified in the privacy policy of the service.
Place of processing: Ireland – Privacy Policy.

XI. Data Subjects’ rights
As a data subject, you have the following rights pursuant to the GDPR: 

Your right of access - You have the right to ask us for copies of your personal information. 

Your right to rectification - You have the right to ask us to rectify information you think is inaccurate. You also have the right to ask us to complete information you think is incomplete. 
Your right to erasure - You have the right to ask us to erase your personal information in certain circumstances. 

Your right to restriction of processing - You have the right to ask us to restrict the processing of your information in certain circumstances. 

Your right to notification - If you have exercised your right to have the Controller rectify, erase, or limit the processing, the Controller shall communicate any rectification or erasure of personal data or restriction of processing to each recipient to whom the personal data concerning you have been disclosed, unless this proves impossible or involves disproportionate effort. You have the right to be informed about those recipients. 
Your right to object to processing - You have the right to object to the processing of your personal data in certain circumstances. Please find further details in the box below this section.
Your right to withdraw consent - You have the right to withdraw your consent at any time. The withdrawal of consent shall not affect the lawfulness of processing based on consent before its withdrawal. 
Your right to data portability - You have the right to ask that we transfer the information you gave us to another organisation, or to you, in certain circumstances.
You are not required to pay any charge for exercising your rights. If you make a request, we have one month to respond to you.
Please reach out to us at the contact details indicated on the App if you wish to make a request.
Your right to file a complaint
You can also complain to a data protection authority if you do not agree on how we have used your data. 


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 Article 6(1)(e) or (f) GDPR; this also applies to profiling based on those provisions. The Controller shall no longer process the personal data unless the Controller demonstrates compelling legitimate grounds for the processing which override the interests, rights and freedoms of the data subject or for the establishment, exercise or defence of legal claims.

XII. Amendments to this privacy notice
Due to the dynamic development of the Internet, new technologies and possibilities are constantly developing. To enable us to offer you these possibilities and technologies, we reserve the right to change this privacy notice for the future when introducing new, additional or when changing or extending existing services or service elements. The new privacy notice shall apply from the date of its update on the App.

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