Privacy

Controller

Paul Buyse, trading as 121 Studios
Heimstättenstraße 3
82166 Gräfelfing
Germany
contact@121-studios.com

In short

The public pages set no cookies, run no analytics and load no third party scripts or fonts. A visit only involves the technical data that every web server processes. The sections under “Not active yet” only apply once the respective function is switched on.

Hosting and server logs

The site is hosted by ALL INKL.COM, Neue Medien Münnich, owner René Münnich, Hauptstraße 68, 02742 Friedersdorf, Germany. The provider states that it uses its own data center in Germany. When you visit, the server processes technically necessary data: IP address, date and time, requested address, amount of data transferred, previously visited page if your browser sends it, and browser and operating system. This serves secure and stable operation. The legal basis is Art. 6 (1) (f) GDPR, our legitimate interest being exactly this operation.

[Retention period of server logs: details to follow] [Data processing agreement under Art. 28 GDPR with the host: confirmation to follow]

Storage in your browser

A local storage entry in your browser is planned for the cart (localStorage, name 121_warenkorb). It only contains the identifier of the chosen map, stays on your device and is not sent to us. As long as nothing can be ordered, it is not created. You can delete it in your browser at any time.

Fonts and images

Fonts, images and scripts are on the same server as the site. Your browser does not connect to other providers for them.

Links to other sites

We link to Discord, gu5.gg and openomsi.org. Data only goes to these providers once you follow the link. Their privacy rules apply there.

Contact

There is no general contact form. You write to us by mail at contact@121-studios.com or kontakt@121-studios.com. If you write to us, we process your details to answer you. The legal basis is Art. 6 (1) (f) GDPR, or (b) for questions about a contract. We delete the details when they are no longer needed and no statutory retention obligation applies.

Withdrawal function

The form on the withdrawal page processes your name, the contract details and your mail address so that you can withdraw from a contract and we can confirm receipt. The legal basis is Art. 6 (1) (c) GDPR in conjunction with Section 356a BGB. The details go by mail to us and to you and are not stored on the web server. We keep the mails as long as necessary as evidence and due to statutory retention obligations. The function is currently in test mode and sends no mail.

To prevent abuse, we store a hashed value of your IP address with the time for each confirmed withdrawal, for one hour at most. The legal basis is Art. 6 (1) (f) GDPR, our legitimate interest being protection against mass abuse. No third party services are involved.

Your rights

You have the right of access (Art. 15 GDPR), rectification (Art. 16), erasure (Art. 17), restriction of processing (Art. 18), data portability (Art. 20) and to object to processing under Art. 6 (1) (f) (Art. 21). You can withdraw any consent at any time with effect for the future. We do not make automated individual decisions under Art. 22 GDPR.

You can also lodge a complaint with a supervisory authority. Responsible for us is the Bavarian State Office for Data Protection Supervision (Bayerisches Landesamt für Datenschutzaufsicht), Promenade 18, 91522 Ansbach, Germany, www.lda.bayern.de.

Retention

Applies to each function once it is active.

• Invoices and accounting vouchers: eight years (Section 147 (3) AO, Section 14b UStG, Section 257 (4) HGB where applicable). Records and books: ten years. Business letters, including those about a purchase: six years. Each period starts at the end of the calendar year (Section 147 (4) AO).
• Evidence of consent, delivery and withdrawal: until the limitation period ends, usually three years from the end of the year (Sections 195, 199 BGB), longer if they belong to the records above.
• Identifier and assignment to the purchase: as long as the purchase records. After an account is deleted they stay linked to the purchase only.
• Tickets not related to a purchase: three years after closing, even after the account is deleted. Find cases: until the matter is settled and any claims are time barred.
• Log of access by the team and stored mails: twelve months. Hash values for rate limiting: one day at most.
• Order without payment including the consent, once sales start: 30 days after it was created. A delayed payment notice can still arrive during this time.
• Order mail with PDF, once sales start: six years from the end of the year in which it was sent (Section 147 (1) no. 3, (3) and (4) AO), longer if it counts as an invoice. Account history: three years from the end of the year of the change.

Account and support

Customer accounts

For your account we process first name and last name, mail address, an unreadable check value of your password, your language, the times of registration, mail confirmation and last sign in, and your consent to the terms of use with version and time. The legal basis is Art. 6 (1) (b) GDPR. Without these details we cannot create an account. The data is stored with our host in Germany.

Cookies. The public pages set no cookies. In the account area and in the administration under /admin we set a session cookie that is strictly necessary for this (Section 25 (2) no. 2 TDDDG). It ends with the browser session. Only if you tick “Stay signed in” yourself when signing in is the cookie konto121_bleiben added, and for the team the cookie adm121_geraet with “Remember this device for 30 days”. It is valid for a fixed 30 days and is not extended. On our side we hold a hash of the random value in the cookie, browser and operating system as a short name, and the times; the entry is removed when the period ends. This is the service you expressly requested (Section 25 (2) no. 2 TDDDG), the legal basis is Art. 6 (1) (b) GDPR, for the team (f).

Protection against abuse. We count attempts to prevent mass sign in attempts and similar abuse. We only store your IP address for this as a non reversible hash value, for one day at most. The legal basis is Art. 6 (1) (f) GDPR, our legitimate interest being the security of the accounts.

Mails. We send mails about your account and requests through our own mail accounts, over an encrypted connection and digitally signed. We record the time, type and result of sending. We store the sent text with your account so that we can trace what we sent you. We do not store one time links, and a license code is never in a mail. We delete these stored mails after twelve months. Once sales start, a longer period applies to the order mail with its PDF, see “Retention”. The legal basis is Art. 6 (1) (b) and (f) GDPR, for the order mail also (c).

History of your account. We record changes to your account: who made them and when, which field is affected, the old and new value and the reason. This serves security and evidence. The legal basis is Art. 6 (1) (f) GDPR. We delete the entries three years after the end of the year in which they were created.

Notify me about updates. This setting is off at first. If you switch it on, we write to you when there is an update. The legal basis is your consent (Art. 6 (1) (a) GDPR), you can switch it off in your account at any time. We inform you about updates we owe you under Section 327f BGB regardless of this (Art. 6 (1) (c) GDPR).

Deleting your account. If you delete your account, your first name and last name, mail address, password, links to other services and the support notes on the account are removed. An empty account number remains. In the history, values and reasons are replaced by “removed”, while type, time and the person handling it remain. For stored mails, the address and content are removed, except for the order mail. Purchases with the details stored there, consents, evidence and tickets stay linked to the empty account number as long as we must or may keep them under “Retention” (Art. 17 (3) (b) and (e) GDPR).

Signing in through Steam

You can voluntarily sign in through Steam or link your account with it. The button takes you to the Steam site of Valve Corporation (USA). You sign in there, we do not see your password. Steam only tells us your SteamID. We ask for your first name, last name and mail address ourselves the first time. We store the SteamID with your account at our host in Germany until you unlink it or delete the account. We do not retrieve your game list or your profile name and do not check whether you own OMSI 2. Processing by Valve is governed by its privacy policy. The legal basis on our side is Art. 6 (1) (b) GDPR.

Signing in through Google

Voluntary. Applies once the “Sign in with Google” button is switched on. As long as it is locked, no data flows to Google.

You can voluntarily sign in through Google or link your account with it. The button takes you to the Google sign in page, you sign in there and we do not see your Google password. Your browser only connects to Google after your click. We request the items openid, email and profile. Google then tells us your Google identifier (sub), your confirmed mail address and your first and last name (given_name, family_name). We store the identifier with your account until you unlink it or delete the account. We only take over the mail address, first name and last name if you create a new account in the process. If an account with the same confirmed mail address already exists, we link it with Google. We do not store a profile picture. The legal basis is Art. 6 (1) (b) GDPR.

Processing by Google is governed by its privacy policy. According to it, the controller for users in the European Economic Area and Switzerland is Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland, and for other users Google LLC, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA. Data can reach the USA in the process. Google states that Google LLC is certified under the EU US Data Privacy Framework and otherwise bases transfers on standard contractual clauses.

Requests and tickets

For a request we process the subject, your texts and our replies, the person handling it, internal team notes, language, status and times, and the related order and account data in order to help you. The legal basis is Art. 6 (1) (b) GDPR, outside a contract (f), our interest being to answer requests.

Who has access on our side

Only Paul Buyse and team members selected by him have access to customer data, only as far as their task requires, following his instructions and bound to confidentiality (Art. 29 and Art. 32 (4) GDPR). We log every view of an account for security and delete these entries after twelve months. The team can add support notes to an account, they are removed when the account is deleted. Notes in a ticket stay with the ticket. The legal basis is Art. 6 (1) (f) GDPR, our legitimate interest being the protection of the data.

Sending mails and confirmation of receipt

Display. The background image and the web fonts Saira and Barlow of our mails are on our server. If your mail program loads them when you open a mail, your IP address reaches our server and this request appears with IP address and time in the server log of our host. The addresses are the same for all recipients, so they do not tell us who opened a mail. The legal basis is Art. 6 (1) (f) GDPR, our legitimate interest being a consistent display. You can switch off loading in your mail program.

Confirmation of receipt. If you write to contact@121-studios.com or kontakt@121-studios.com, we reply automatically once to say that your message has been received. For this our server only reads header lines of your mail, such as the sender and indications of automatic mails, and does not store them. So that you do not receive several replies, we only keep your sender as a hash value, for 24 hours. Automatic mails and mailing lists do not receive a reply. The legal basis is Art. 6 (1) (f) GDPR, our legitimate interest being to confirm receipt.

Not active yet

The following sections describe functions that are currently not active. No data flows for them yet. We state here what will apply once the respective function starts.

Purchases and payment through Stripe

Not active yet. Applies once sales start.

A purchase requires an account. For it we process order number, map, price, country, mail address, times, your consent to early performance with wording and time, and the payment identifiers at Stripe. The legal basis is Art. 6 (1) (b) GDPR, (c) for tax records, (c) and (f) for evidence of your consent.

You pay on a page run by Stripe, our contract partner is Stripe Payments Europe, Limited (Ireland). You enter your payment details there directly, we do not see or store them. According to its data processing agreement, Stripe processes data partly as our processor and partly under its own responsibility, for example for fraud prevention and working with banks. Stripe states that data can also reach the USA and bases transfers among others on the EU US Data Privacy Framework and on standard contractual clauses. For VAT, Stripe determines your country from your details at payment, for example your billing address. More is in the Stripe privacy policy. If you pay with PayPal, you also enter details at PayPal (Europe) S.à r.l. et Cie, S.C.A. in Luxembourg, where the PayPal privacy policy applies. If you pay with Revolut Pay, you confirm the payment at Revolut, where the Revolut privacy policy applies.

License code, mails and download

Not active yet. Applies once sales start.

We send you the order confirmation by mail through our host, it contains no code. In the order we record which of the two buttons “Redeem in my account” and “Pass code on to someone else” was used and when, and who displayed or redeemed the code and when. Paid codes are stored encrypted so that they remain retrievable in the order. For each download we store the purchase, account, time and version of the map, but no IP address. We need this as evidence of supply and of the start of performance (Sections 327b (6) and 356 (6) BGB). The legal basis is Art. 6 (1) (b) and (f) GDPR.

Codes passed on. If another person redeems the code, we link the purchase to their account. For the redeeming person we process their account data, the time and the downloads. We do not tell the buyer who redeemed the code, only whether and when it was redeemed. We do not give the redeeming person any data about the buyer. The legal basis is Art. 6 (1) (b) GDPR, and (f) for linking both records to protect against abuse. We only pass on data as far as necessary for legal action.

The map itself is stored in Cloudflare R2 of Cloudflare, Inc. (USA), in the area set for the EU. For your purchase a package with the identifier is created there, it is deleted again after three days and recreated if needed. For the download we create a signed link that is valid for 24 hours. It contains no name and no mail address, but anyone who has it can download during this time, so do not pass it on. During the download, Cloudflare processes your IP address and technical request data as our processor. The download address therefore shows Cloudflare and not our domain. The agreement with Cloudflare bases transfers to the USA on the EU US Data Privacy Framework and on standard contractual clauses.

Identifier in the map

Not active yet. Applies once sales start.

Delivered copies contain an identifier assigned to the respective purchase. It is fixed per purchase and stays the same for every new download. If a copy is published without permission, it lets us determine which purchase the copy comes from. The identifier itself contains no details about you. The assignment to the purchase and to the account in which the code was redeemed exists only with us, so for us this is personal data. A find only shows which purchase the files come from, not who published them. We do not say where the identifier is located, because it would otherwise lose its purpose.

The legal basis is Art. 6 (1) (f) GDPR. Our legitimate interest is protecting our map against unauthorized passing on. You can object under Art. 21 GDPR on grounds relating to your particular situation. On request we tell you under Art. 15 GDPR the data stored for your purchase, including the value of the identifier. In case of a find we also process the location, date and checksum of the find and report the publication to the provider concerned. We only pass on purchase data as far as necessary for legal action, for example to lawyers or courts.