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Privacy Policy

Note: due to severe lack of time, this privacy statement is provided only in English until further notice.

Old version (stills applicable, but not GDPR compliant)

Privacy

Besides your logo configuration and your flag collection, only your user name and team id and the CHPP tokens are stored. This data is not shared with anyone (well, technically employees of our hoster have access to the data and there is no way for us to prevent this). To keep you logged in a browser cookie is required. This will expire when you close your browser, deleting it will only force you to authenticate again (if you haven't chosen automatic login or deleted the persistent cookie), and your chosen language will be forgotten. The automatic login feature prevents that you have to authenticate at chpp.hattrick.org on every visit (which leads to an ingame message), therefore a persistent cookie is required. If this cookie is deleted, you'll have to authenticate again. The lifetime of this cookie is one month, after that the automatic login is no longer possible.

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TL;DR Version

• I'm just one guy doing this in my spare time (yes, I write 'we' in the following, because maybe there will be a 'we' at a later date. Don't take it too seriously. there might even be an 'employees' left in the legalese version, because I forgot to remove it. Please ignore that. There are no employees, as this is not a business).
• All services offered here are free of charge and without hidden agenda.
• You need a HT account to access the site (except some pages).
• All Data collected/stored is required for the provided functionality.
• No analytics software or any other way of analyzing your data (except which is displayed to you) is used.
• No third party resouces are loaded on our pages. There are no ads.
• No data is shared with third parties, except
  • data is submitted to HT via the API interface. All data we submit (e.g. user id, team id) is already known to HT.
  • Our hosting provider has full access to all data. We know nothing about their internal procedures or whom of their employees have access, except that they provide statistics based on server logs, and they store all IP addresses for at most seven days, in order to 'detect and prevent attacks'. Of course, as a German company with all servers located in Germany, Strato is subject to the GDPR and all German privacy laws and regulations. See their website/privacy statement for more details.
    We concluded an agreement for the outsourcing of data processing with Strato for GDPR compliance.
  • We might be required to share data with law enforcement at some point in the future, but considering the nature of our services, that seeems really unlikely ;)
• We (I) take your privacy rights seriously. They are important and I will do my best to fulfill all legal obligations (and more).
• See the Optout section at the end of this page if you want to delete all data associated with you.
• Note that HT does not consider any of the data shared via CHPP as private. At least there is a forum post that says so (17182782.5 in the CHPP forum,only accessible as a CHPP developer, but that is only from a Mod and not marked as official...), and they don't mention CHPP at all in their own privacy statement.
  Besides CHPP data (esp. username, user id), the only dta that might be considered private is what you enter in the settings page; e.g. if the given image shows you. But only the URL to the image is stored, not the image itself.

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Legalese Version

This is a private website that offers helpful services for the online game Hattrick (hereinafter call HT). There is no interest in spying on you or collecting any data except those mandatory for the functionality of the offered services. Most of the stored data can hardly be considered personal, some of it however might be; for details see below.

Processing of personal data shall always be in line with the General Data Protection Regulation (GDPR), and in accordace with the country-specific data protection regulations applicable. By means of this data protection declaration, we would like to inform the general public of the nature, scope, and purpose of the personal data we collect, use and process. Furthermore, data subjects are informed, by means of this data protection declaration, of the rights to which they are entitled.

We have implemented numerous technical and organizational measures to ensure the most complete protection of personal data processed through this website. However, Internet-based data transmissions may in principle have security gaps, so absolute protection may not be guaranteed.
Since all personal data is fetched from HT via CHPP API, there is no way to submit data other than that.

1. Definitions

This data protection declaration is based on the terms used by the European legislator for the adoption of the General Data Protection Regulation (GDPR). Our data protection declaration should be legible and understandable for the general public, as well as our users.

In this data protection declaration, we use, inter alia, the following terms:

• a) Personal data

  Personal data means any information relating to an identified or identifiable natural person (“data subject”). An identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.

• b) Data subject

  Data subject is any identified or identifiable natural person, whose personal data is processed by the controller responsible for the processing (aka you).

• c) Processing

  Processing is any operation or set of operations which is performed on personal data or on sets of personal data, whether or not by automated means, such as collection, recording, organisation, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction.

• d) Restriction of processing

  Restriction of processing is the marking of stored personal data with the aim of limiting their processing in the future.

• e) Profiling

  Profiling means any form of automated processing of personal data consisting of the use of personal data to evaluate certain personal aspects relating to a natural person, in particular to analyse or predict aspects concerning that natural person's performance at work, economic situation, health, personal preferences, interests, reliability, behaviour, location or movements.

• f) Pseudonymisation

  Pseudonymisation is the processing of personal data in such a manner that the personal data can no longer be attributed to a specific data subject without the use of additional information, provided that such additional information is kept separately and is subject to technical and organisational measures to ensure that the personal data are not attributed to an identified or identifiable natural person.

• g) Controller or controller responsible for the processing

  Controller or controller responsible for the processing is 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; where the purposes and means of such processing are determined by Union or Member State law, the controller or the specific criteria for its nomination may be provided for by Union or Member State law.

• h) Processor

  Processor is a natural or legal person, public authority, agency or other body which processes personal data on behalf of the controller.

• i) Recipient

  Recipient is a natural or legal person, public authority, agency or another body, to which the personal data are disclosed, whether a third party or not. However, public authorities which may receive personal data in the framework of a particular inquiry in accordance with Union or Member State law shall not be regarded as recipients; the processing of those data by those public authorities shall be in compliance with the applicable data protection rules according to the purposes of the processing.

• j) Third party

  Third party is a natural or legal person, public authority, agency or body other than the data subject, controller, processor and persons who, under the direct authority of the controller or processor, are authorised to process personal data.

• k) Consent

  Consent of the data subject is any freely given, specific, informed and unambiguous indication of the data subject's wishes by which he or she, by a statement or by a clear affirmative action, signifies agreement to the processing of personal data relating to him or her.

2. Name and Address of the controller

Controller for the purposes of the General Data Protection Regulation (GDPR), other data protection laws applicable in Member states of the European Union and other provisions related to data protection is:

The HT user mindw0rm

Email: mindw0rm@fcclogo.kaoztribe.net [Note: HT mail is preferred! Use email only if your HT account is no longer accessible.]

3. Cookies

This website uses the following cookies to keep track of your session:

• PHPSESSIONID: this session cookie (lifetime ends afther you close the browser) assignes a unique ID to you that is required to determine that you are you.
• loginInfo: this permanent cookie (lifetime 30 days) contains a random value associated with your account. It is only set if you chose the login automatically option during login. This is required to identify you and log you in on visits in future sessions. This cookie is deleted when you log off (or don't log in for more than 30 days).

The session cookie is mandatory for the provided functionality (except for pages that are reachable without login). Deleting this cookie will log you out, but it will be automatically set again (with a different value) with your nest visit.
The autologin cookie is optional and will only be set if you explicitly choose so during login.

4. Collection of general data and information

Our website collects a series of general data and information when a data subject or automated system calls up the website. This general data and information are stored in the server log files. Collected may be (1) the browser types and versions used, (2) the operating system used by the accessing system, (3) the website from which an accessing system reaches our website (so-called referrers), (4) the sub-websites, (5) the date and time of access to the Internet site, (6) an Internet protocol address (IP address), (7) the Internet service provider of the accessing system, and (8) any other similar data and information that may be used in the event of attacks on our information technology systems.
The server log files are managed and maintained by our webhosting provider Strato AG and cannot be prevented by us.
The IP address should be the only data considered personal information, and thet is deleted after at most seven days according to their info. The server and every other system that might get in contact with your data du to internal procedures of our hosting provider is located in Germany. None of the data is transfered to another country, except to your web browser when you access the pages.
An agreement with Strato for the outsourcing of data processing was concluded.

Except from the server logs, none of this data is processed by the website itself, with the exception of the user agent (to handle OS specific quirks) and the submitted form and URL data (aka GET and POST data). The submitted data is mandatory to ensure full functionality of the services. Most of the submitted data is also stored permanently until you change it or use the Optout functionality provided below.

5. Registration on our website

Registration/Login is handled via CHPP oAuth. For this purpose, you are redirected to the CHPP login page, where you log in with your HT credentials. After a successful submit, the CHPP page redirects back to us to provide us with oauth tokens, that can be used to access data via the CHPP API. The password entered on the CHPP site is never submitted to us.
Note that HT does not consider any of this data (including your username) as personal data, so they don't even mention CHPP in their privacy statement. While we can understand this viewpoint, we consider some of the data, namely your HT username, as personal data according to this privacy statement. This data is stored permanently, along with the latest oAuth tokens, untill you request a delete (see below). None of the data is shared with anythird party except of HT: we require both the oAuth tokens and you team ID(s) to fetch the data required to provide our services (namely the flag collection).

The registration of the data subject, with the voluntary indication of personal data, is intended to enable the controller to offer the data subject contents or services that may only be offered to registered users due to the nature of the matter in question. Registered persons are free to have all data associated with them completely deleted from the data stock of the controller.

The data controller shall, at any time, provide information upon request to each data subject as to what personal data are stored about the data subject. In addition, the data controller shall correct or erase personal data at the request or indication of the data subject, insofar as there are no statutory storage obligations.

6. Routine erasure and blocking of personal data

There is no routine erasure/blocking implemented yet. If you want your data deleted, you need to request it manually (see below).

7. Rights of the data subject

• a) Right of confirmation

  Each data subject shall have the right granted by the European legislator to obtain from the controller the confirmation as to whether or not personal data concerning him or her are being processed. If a data subject wishes to avail himself of this right of confirmation, he or she may, at any time, contact the controller.

• b) Right of access

  Each data subject shall have the right granted by the European legislator to obtain from the controller free information about his or her personal data stored at any time and a copy of this information. Furthermore, the European directives and regulations grant the data subject access to the following information:

  • the purposes of the processing;
  • the categories of personal data concerned;
  • the recipients or categories of recipients to whom the personal data have been or will be disclosed, in particular recipients in third countries or international organisations;
  • where possible, the envisaged period for which the personal data will be stored, or, if not possible, the criteria used to determine that period;
  • the existence of the right to request from the controller rectification or erasure of personal data, or restriction of processing of personal data concerning the data subject, or to object to such processing;
  • the existence of the right to lodge a complaint with a supervisory authority;
  • where the personal data are not collected from the data subject, any available information as to their source;
  • the existence of automated decision-making, including profiling, referred to in Article 22(1) and (4) of the GDPR and, at least in those cases, meaningful information about the logic involved, as well as the significance and envisaged consequences of such processing for the data subject.

  Furthermore, the data subject shall have a right to obtain information as to whether personal data are transferred to a third country or to an international organisation. Where this is the case, the data subject shall have the right to be informed of the appropriate safeguards relating to the transfer.

  If a data subject wishes to avail himself of this right of access, he or she may, at any time, contact any employee of the controller.

• c) Right to rectification

  Each data subject shall have the right granted by the European legislator to obtain from the controller without undue delay the rectification of inaccurate personal data concerning him or her. Taking into account the purposes of the processing, the data subject shall have the right to have incomplete personal data completed, including by means of providing a supplementary statement.

  If a data subject wishes to exercise this right to rectification, he or she may, at any time, contact any employee of the controller.

• d) Right to erasure (Right to be forgotten)

  Each data subject shall have the right granted by the European legislator to obtain from the controller the erasure of personal data concerning him or her without undue delay, and the controller shall have the obligation to erase personal data without undue delay where one of the following grounds applies, as long as the processing is not necessary:

  • The personal data are no longer necessary in relation to the purposes for which they were collected or otherwise processed.
  • The data subject withdraws consent to which the processing is based according to point (a) of Article 6(1) of the GDPR, or point (a) of Article 9(2) of the GDPR, and where there is no other legal ground for the processing.
  • The data subject objects to the processing pursuant to Article 21(1) of the GDPR and there are no overriding legitimate grounds for the processing, or the data subject objects to the processing pursuant to Article 21(2) of the GDPR.
  • The personal data have been unlawfully processed.
  • The personal data must be erased for compliance with a legal obligation in Union or Member State law to which the controller is subject.
  • The personal data have been collected in relation to the offer of information society services referred to in Article 8(1) of the GDPR.

  If one of the aforementioned reasons applies, and a data subject wishes to request the erasure of personal data stored by the none whatsoever, he or she may, at any time, contact any employee of the controller. An employee of none whatsoever shall promptly ensure that the erasure request is complied with immediately.

  Where the controller has made personal data public and is obliged pursuant to Article 17(1) to erase the personal data, the controller, taking account of available technology and the cost of implementation, shall take reasonable steps, including technical measures, to inform other controllers processing the personal data that the data subject has requested erasure by such controllers of any links to, or copy or replication of, those personal data, as far as processing is not required. An employees of the none whatsoever will arrange the necessary measures in individual cases.

• e) Right of restriction of processing

  Each data subject shall have the right granted by the European legislator to obtain from the controller restriction of processing where one of the following applies:

  • The accuracy of the personal data is contested by the data subject, for a period enabling the controller to verify the accuracy of the personal data.
  • The processing is unlawful and the data subject opposes the erasure of the personal data and requests instead the restriction of their use instead.
  • The controller no longer needs the personal data for the purposes of the processing, but they are required by the data subject for the establishment, exercise or defence of legal claims.
  • The data subject has objected to processing pursuant to Article 21(1) of the GDPR pending the verification whether the legitimate grounds of the controller override those of the data subject.

  If one of the aforementioned conditions is met, and a data subject wishes to request the restriction of the processing of personal data stored by the none whatsoever, he or she may at any time contact any employee of the controller. The employee of the none whatsoever will arrange the restriction of the processing.

• f) Right to data portability

  Each data subject shall have the right granted by the European legislator, to receive the personal data concerning him or her, which was provided to a controller, in a structured, commonly used and machine-readable format. He or she shall have the right to transmit those data to another controller without hindrance from the controller to which the personal data have been provided, as long as the processing is based on consent pursuant to point (a) of Article 6(1) of the GDPR or point (a) of Article 9(2) of the GDPR, or on a contract pursuant to point (b) of Article 6(1) of the GDPR, and the processing is carried out by automated means, as long as the processing is not necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in the controller.

  Furthermore, in exercising his or her right to data portability pursuant to Article 20(1) of the GDPR, the data subject shall have the right to have personal data transmitted directly from one controller to another, where technically feasible and when doing so does not adversely affect the rights and freedoms of others.

  In order to assert the right to data portability, the data subject may at any time contact any employee of the none whatsoever.

• g) Right to object

  Each data subject shall have the right granted by the European legislator to object, on grounds relating to his or her particular situation, at any time, to processing of personal data concerning him or her, which is based on point (e) or (f) of Article 6(1) of the GDPR. This also applies to profiling based on these provisions.

  The none whatsoever shall no longer process the personal data in the event of the objection, unless we can demonstrate 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.

  If the none whatsoever processes personal data for direct marketing purposes, the data subject shall have the right to object at any time to processing of personal data concerning him or her for such marketing. This applies to profiling to the extent that it is related to such direct marketing. If the data subject objects to the none whatsoever to the processing for direct marketing purposes, the none whatsoever will no longer process the personal data for these purposes.

  In addition, the data subject has the right, on grounds relating to his or her particular situation, to object to processing of personal data concerning him or her by the none whatsoever for scientific or historical research purposes, or for statistical purposes pursuant to Article 89(1) of the GDPR, unless the processing is necessary for the performance of a task carried out for reasons of public interest.

  In order to exercise the right to object, the data subject may contact any employee of the none whatsoever. In addition, the data subject is free in the context of the use of information society services, and notwithstanding Directive 2002/58/EC, to use his or her right to object by automated means using technical specifications.

• h) Automated individual decision-making, including profiling

  Each data subject shall have the right granted by the European legislator not to be subject to a decision based solely on automated processing, including profiling, which produces legal effects concerning him or her, or similarly significantly affects him or her, as long as the decision (1) is not is necessary for entering into, or the performance of, a contract between the data subject and a data controller, or (2) is not authorised by Union or Member State law to which the controller is subject and which also lays down suitable measures to safeguard the data subject's rights and freedoms and legitimate interests, or (3) is not based on the data subject's explicit consent.

  If the decision (1) is necessary for entering into, or the performance of, a contract between the data subject and a data controller, or (2) it is based on the data subject's explicit consent, the none whatsoever shall implement suitable measures to safeguard the data subject's rights and freedoms and legitimate interests, at least the right to obtain human intervention on the part of the controller, to express his or her point of view and contest the decision.

  If the data subject wishes to exercise the rights concerning automated individual decision-making, he or she may, at any time, contact any employee of the none whatsoever.

• i) Right to withdraw data protection consent

  Each data subject shall have the right granted by the European legislator to withdraw his or her consent to processing of his or her personal data at any time.

  If the data subject wishes to exercise the right to withdraw the consent, he or she may, at any time, contact any employee of the none whatsoever.

8. Legal basis for the processing

Art. 6(1) lit. a GDPR serves as the legal basis for processing operations for which we obtain consent for a specific processing purpose. If the processing of personal data is necessary for the performance of a contract to which the data subject is party, as is the case, for example, when processing operations are necessary for the supply of goods or to provide any other service, the processing is based on Article 6(1) lit. b GDPR. The same applies to such processing operations which are necessary for carrying out pre-contractual measures, for example in the case of inquiries concerning our products or services. Is our company subject to a legal obligation by which processing of personal data is required, such as for the fulfillment of tax obligations, the processing is based on Art. 6(1) lit. c GDPR. In rare cases, the processing of personal data may be necessary to protect the vital interests of the data subject or of another natural person. This would be the case, for example, if a visitor were injured in our company and his name, age, health insurance data or other vital information would have to be passed on to a doctor, hospital or other third party. Then the processing would be based on Art. 6(1) lit. d GDPR. Finally, processing operations could be based on Article 6(1) lit. f GDPR. This legal basis is used for processing operations which are not covered by any of the abovementioned legal grounds, if processing is necessary for the purposes of the legitimate interests pursued by our company or by a third party, except where such interests are overridden by the interests or fundamental rights and freedoms of the data subject which require protection of personal data. Such processing operations are particularly permissible because they have been specifically mentioned by the European legislator. He considered that a legitimate interest could be assumed if the data subject is a client of the controller (Recital 47 Sentence 2 GDPR).

9. The legitimate interests pursued by the controller or by a third party

Where the processing of personal data is based on Article 6(1) lit. f GDPR our legitimate interest is to provide our services.

10. Period for which the personal data will be stored

Anydata will be stored until you explicitly request a delete. Even if your HT accound is no longer accessible, wh will still keep the data (there is no automation to check if an account is still accessible).

11. Provision of personal data as statutory or contractual requirement; Requirement necessary to enter into a contract; Obligation of the data subject to provide the personal data; possible consequences of failure to provide such data

We clarify that the provision of personal data is required to provide our services.

12. Existence of automated decision-making

We do not use automatic decision-making or profiling. We don't even use any access analysis.

This Privacy Policy is based of one that has been generated by the Privacy Policy Generator of the External Data Protection Officers that was developed in cooperation with the Media Law Lawyers from WBS-LAW. [but modified by us, since alas, we are no business. Any mistakes herein are made by us. Thanks for the service!]

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Optout

This feature requires that you are logged in.

If you cannot login, because your HT account is no longer accessible, please send an email to mindw0rm@fcclogo.kaoztribe.net. If your account is indeed no longer accessible (i.e. shown as "a former user" in HT), we will delete all data associated with it. If Your name is still shown, we will ask a GM, if this account is indeed not accessible, but cannot guarantee that they will answer - afaik there is a strict 'no info on locked accounts' policy in HT, but maybe they make an exception in that case. It will be helpful if you send the mail from the email address that you used to register at HT. We will share your email address with the GM, but ask for your consent first.
If the given account still seems accessible, we will assume you are just trolling us, and deny your deletion request; except if you can provide some solid proof that this is indeed your account. We have no idea how this proof may look like.
Maybe contact HT and persuade them to forward the deletion request to us.