Global Privacy Policy
Version July 2024
1. General information
CapStar Games is committed to protecting the privacy of everyone who uses our website and applications. The website of CapStar Games can be used around the world. Privacy and data protection requirements vary by country. No matter where your personal data is processed, we believe it is important to provide the same level of protection as described in this privacy statement, which now applies to all countries outside the European Union and the United Kingdom. This Privacy Statement - Global Privacy Statement, abbreviated as Privacy Statement - aims to provide transparency for the privacy practices and principles of CapStar Games. It provides data information we collect from website visitors through h5gamesmaster.com and other general audience websites and applications (collectively referred to as "CapStar Games").
CapStar Games is specifically designed for website visitors aged 16 and above ("website visitors"). If you are under 16 years old, this website is not applicable to you.
The CapStar Games website is owned and operated by the CapStar Games Company (referred to as "CapStar Games", "us", "we" or "our" in this privacy statement).
*Please note that we determine the region where you visit our website based on your IP address, so if you use a VPN connection, the privacy statement applicable to you may not be displayed.
2. What data was used and for what purpose?
All features on the CapStar Games website can be used without the need for website visitors to register. Unless website visitors proactively contact us, we will not request or process any contact information from them, such as your name, email address, and phone number. In addition, our game developers are generally required to remove all outgoing links and brand/advertisements (such as splash screens, social links, and app store links) from their games.
Nevertheless, CapStar Games did collect some electronic data. We can process this data in various ways. Please find some general information about how we process your data directly below. Below, you can find an overview of various topics that you can click on to obtain more detailed information about processing your information in specific environments.
General processing purpose
Generally speaking, we may always process your data for the following purposes:
Used for maintenance, management, network and security purposes;
l Used for internal control and business operations;
l Used for analyzing and improving our products;
l Handle any requests, complaints, and disputes;
l Decide, exercise, and defend our rights; and
l Comply with legal obligations (including fraud prevention) and requirements of authorized government agencies.
General processing grounds
In general, we may process your data based on a legal obligation. This means that we will process your data for as far as we are legally obliged to do so, for instance to comply with statutory minimum retention periods.
Legitimate interest
Sometimes we indicate that we process your data based on the legal ground "legitimate interest". This means that a balance of interests is performed between the interests that are served by the processing on the one hand and your privacy interests on the other hand, and that the interests in favor of the processing prevail. The related legitimate interests are included below per topic. If you want more information about this, you can contact us directly via our contact details stated below.
Minors and other persons with a legal representative
The CapStar Games Website is not meant for persons younger than 16 years. We also do not focus on persons who are placed under a legal relationship, such as guardianship or persons who are supervised or administered by someone else. If, in exceptional cases, we could focus on such persons, CapStar Games will take into account the vulnerable position of these persons and take extra precautions.
3. How do we obtain your data?
We obtain your data in various ways:
l Provided by you. Some data about you, we receive straight from you. Examples include information in your messages to us and information you enter in our application form.
l Obtained internally. It is possible that we obtain your data via other CapStar Games systems. An example for game developers is the data which is included into our CRM system.
l Obtained from third parties. We could also obtain data about you from other persons or external parties. Specifically, we make use of this possibility in two scenarios:
Website Visitors: we may receive information about you from privately held third parties, such as for the advertisements that are shown on the CapStar Games Website. Further information on this is included in our Cookie Statement.
Applicants: we may obtain information from a referral included by you in your application.
l Automatically obtained. Some data we obtain automatically, for example by using cookies and similar techniques. When your computer or mobile device contacts our web servers (e.g. when you visit the CapStar Games Website), our web servers automatically collect usage information. Such usage information includes information about how our Website Visitors use and navigate the CapStar Games Website. It can include the number and frequency of Website Visitors to each web page and the length of their stays, browser type, and referrer data that identifies the web page visited prior and subsequent to visiting the CapStar Games Website. Further information on this is included in our Cookie Statement.
l Derived. Certain data we do not receive directly, but can be derived from the information already in our possession. For example, information about your language preferences.
In principle you are under no obligation to provide any information about yourself to us. However, refusal to supply certain information could have a negative influence on, for example, the functionality of the CapStar Games Website. If the provision of certain personal data is a legal or contractual obligation or an essential requirement for concluding an agreement with us, we will separately provide additional information about this for as far as this is not clear in advance. In such case we will also inform you about the possible consequences if this information is not provided.
4. Who do we share your data with?
We only share your data with third parties if:
l This is necessary for the provision of a service or the involvement of the third party. Sub-contractors, for example, will in principle only get access to the data that they require for their part of the service provision.
l The persons within the third party that have access to the data are under an obligation to treat your data confidentially. Where necessary this is also contractually agreed on.
l The third party is obliged to comply with the applicable regulations for the protection of personal data, for instance because we have concluded an agreement with this party or because our Terms of Use apply. This includes that the party is obliged to ensure appropriate technical and organizational security measures.
We could share your data on a need-to-know basis with the parties mentioned below. In this context, "need-to-know" means that a party only gets access to your data if and insofar as this is required for the professional services provided by this party.
l Authorized persons, employed by CapStar Games, who are involved with the processing activity concerned. Such as, the members of the support team you are in contact with.
l Authorized persons, employed by service providers / sub-contractors engaged by CapStar Games , who are involved with the processing activity concerned. Such as, the service provider for the CapStar Games web shop.
l Authorized persons, employed by parties in the private sector with whom we may share certain data, such as our game developers and advertising partners. Traffic information may be shared with game developers and advertisers on an aggregate and anonymous basis. In addition, advertisers on the CapStar Games Website may receive information gathered by cookies for targeted advertising purposes. Further information regarding the use of cookies can be found in our Cookie Statement.
l Authorized government institutions. Such as, courts, police, and law enforcement agencies. We may release information about our Website Visitors, when legally required to do so, at the request of governmental institutions conducting an investigation or to verify or enforce compliance with the policies governing the CapStar Games Website and applicable law. We may also disclose such user information whenever we believe disclosure is necessary to protect the rights, property or safety of CapStar Games, or any of our respective business partners, customers or others.
l Aggregate Information. We may also disclose non-identifying, aggregated user statistics to third parties for a variety of purposes, including describing our services to prospective partners and other third parties. Examples of such non-personal information include the number of users who visited this CapStar Games Website during a specific time period or played a specific game.
5. How do we secure your data?
Protecting your privacy and data is very important to us. Therefore, CapStar Games has implemented appropriate technical and organizational measures to protect and secure personal data, in order to prevent violations of the confidentiality, integrity and availability of the data. All CapStar Games employees and other persons engaged by CapStar Games for the processing of data are obliged to respect the confidentiality of personal data.
CapStar Games has internal documentation in which it is described how we safeguard an appropriate level of technical and organizational security. In addition, a data breach procedure is applicable within CapStar Games, in which it is explained how (potential) data breaches need to be handled. We will, for example, inform the competent supervisory authority and involved data subjects when this is required by the applicable law.
6. To which countries will we transfer your data?
Parties involved with the processing of your data may be located in a different country than you are. No matter where you are located, we are securing your personal data as much as reasonably possible.
If your data is transferred from the EU to a party located outside the EU, we call this an 'EU transfer'. If your data is transferred from the UK to a party located outside the UK, we call this a 'UK transfer'. EU transfers and UK transfers are legitimized in the manner described below. You may contact us for information on the legitimization of other data transfers.
EU transfers. An EU transfer EU can in the first place be legitimized based on an adequacy decision of the European Commission, in which it is decided that the (part within the) third country in question ensures an adequate level of data protection.
UK transfers. A UK transfer can in the first place be legitimized based on an adequacy regulation of the UK government.
If an EU transfer and/or UK transfer takes place for which there is no adequacy decision or adequacy regulation in place, we agree on the applicability of the relevant version of the Standard Contractual Clauses with the relevant party. This is a standard contract to safeguard the protection of your data, which is approved by the European Commission in which the parties fill out the appendices. Where appropriate, additional safeguards should be taken. Where the UK GDPR is applicable, a UK Addendum will be added to the Standard Contractual Clauses mentioned above, as required by UK law and regulations.
In specific situations we can also rely on the derogations as specified in applicable law to legitimize the EU transfer and/or UK data transfer. This could mean that we may transfer your data: (i) with your explicit consent, (ii) if this is necessary for the performance of a contract that has been concluded with you or has been concluded in your interest, or (iii) if this is necessary for the establishment, exercise or defense of legal claims. Lastly, in exceptional cases we may also transfer your data if the data transfer is necessary for our compelling legitimate interests and is not overridden by your interests or rights and freedoms.
You can contact us if you want additional information via our contact details as stated at the bottom of this Privacy Statement.
Google Analytics Blockage Blockage Please note that we do not use Google Analytics on any of our websites. However, it is possible that one of the game developers we work with tries to use Google Analytics for tracking in-game activities. We actively try to find these implementations and overwrite them for users from the EU. To opt out of being tracked by Google Analytics across all websites, please visit: http://tools.google.com/dlpage/gaoptout.
7. How do we determine how long we retain your data?
In general, we do not keep your data for longer than what is necessary in relation to the purposes for which we process the data. There could however be exceptions applicable to the general retention terms.
Exception: shorter retention period. If you exercise certain privacy rights, it is possible that CapStar Games will remove your data earlier than the general applicable retention period or – oppositely – retain it for a longer period of time. For more information about this, please refer to the header "What are your privacy rights (incl. right to object)?"
Exception: longer retention period. In certain situations, we process your data for a longer period of time than what is necessary for the purpose of the processing. This is for instance the case when we have to process your data for a longer period of time:
l Retention obligation. To comply with a minimum retention period or other legal obligation to which we are subject based on the applicable law;
l Procedure. Your personal data is necessary in relation to a legal procedure;
l Freedom of expression. When further processing of your personal data is necessary in order to exercise the right to freedom of expression and information.
8. What are your privacy rights (including the right to object)?
You have various privacy rights. The privacy rights you have depend on the applicable laws. The extent to which you can exercise these rights may depend on the processing situation, such as the way CapStar Games processes personal data and the legal basis for processing. The following is a summary of the privacy rights you may have. Applicable laws may allow or require us to refuse your request, as these rights are not absolute or may not apply to your region.
For more information about your privacy rights in other jurisdictions such as EU member states or the UK.
9. Who is responsible for processing your data?
CapStar Games is generally responsible for processing your data on the CapStar Games website, but other parties may also participate and be responsible for it, as described below.
9.1 Developers.
In principle, developers of games on the CapStar Games website must remove all outgoing links and brand/advertisements (such as splash screens, social links, and app store links) from the game. If developers do collect personal data for their own purposes, CapStar Games is not responsible for processing it: only the developers decide what (personal) data to process and for what purpose. However, because CapStar Games believes that your data is also secure while playing the game, which is important, we have taken two measures. Firstly, we have signed a contract protection clause with the developer. They only allow cookies and similar technologies to be included in the game if consent is not required by applicable law. Regarding the analysis of cookies, the use of such cookies is only allowed when it complies with applicable laws and the privacy impact is non-existent or minimal. Secondly, we have prepared a list of cookies used by game developers, categorized by game, to notify you on behalf of the developers* For more information about developer cookies, please refer to our cookie statement. In addition, if you notice any possible improper handling of your data by developers, please notify us so that we can investigate.
9.2 Advertising partners.
CapStar Games uses services from multiple advertisers. We provide advertisements for the CapStar Games website in these directions and are responsible for processing your data in this situation. Nevertheless, in order to protect your privacy as much as possible in this regard, CapStar Games has ensured that appropriate contractual measures are taken. More information about cookie usage, as well as in the case of advertising partners, can be found in our cookie statement.
9.3 External hosted games, third-party games, and other websites.
This privacy statement does not apply to other parties responsible for the use of your data, such as third-party game providers on the CapStar Games website, who use your data. The relevant providers of such third-party games are responsible for ensuring that any processing of your data in the game complies with applicable laws. In principle, CapStar Games does not allow third-party content providers to collect personal data of website visitors. However, if any personal data will be collected by third-party content providers, CapStar Games will require that their processing of such data complies with applicable laws.
*Please note that this list may not be complete as random cookies with less than 100 website visitors are not included in the list. In addition, the cookies used by developers may change over time. Therefore, we automatically update this list every day.