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Legal Notice
Information according to Section 5 Digitale-Dienste-Gesetz (DDG):
Service provider: funline MEDIA GmbH
Am Bichel 10
DE - 82234 Weßling-Hochstadt
Germany
Management: Stefanie Stalf, Roland Ressemann
Commercial register: Amtsgericht München, HRB 210919
VAT ID No.: DE294909440
Alternative dispute resolution for consumers: The European Commission operates a platform for online dispute resolution (until 20 July 2025), which is available at http://ec.europa.eu/consumers/odr/. We are not legally obliged to participate in a dispute resolution procedure before a consumer arbitration board and are generally not prepared to do so.
Copyright and rights of use
Notes on intellectual property:
The content of our websites and our apps (text, images, audio, video) are protected by copyright in accordance with Sections 2, 72, 85, 95 UrhG. Our apps are protected as computer programmes in accordance with Section 69a UrhG.
You may only use this content with our consent, apart from the exceptional cases regulated by law (limitations of copyright, §§ 44a UrhG ff.).
If you have purchased an app, you and other people who belong to your family or the same household are authorised to use it. You may install the app on multiple devices. If you have only purchased the app once, the app may not be used by several people at the same time.
In particular, you are not authorised to distribute the content or the apps (e.g. online), whether for a fee or free of charge, or to edit them.
You may not change or remove copyright notices.
Cookie Settings:
Privacy policy:
Information in accordance with Article 13 of the General Data Protection Regulation (GDPR):
Please find in sections 1, 5, 6 and 7 general information on the controller, the processing of personal data that you provide, the period of storage and your rights as a data subject.
Section 2 contains information on the processing of personal data when you use our websites.
Section 3 contains information on the processing of personal data when you use our websites.
Section 4 contains information on the processing of personal data when you use our social media profiles.
1. Responsible person, contact details
funline Media GmbH (Management: Stefanie Stalf, Roland Ressemann)
2. Processing of personal data when you use our websites
You can visit our websites without providing any personal information, but personal data may be processed when you access a website (see 2.2 ).
If you send us a message via a contact form or by other means, we process the data that you provide (see 5.).
2.1 Server log files
The website provider collects and stores in server log files certain information that your browser transmits. This includes
· browser type and browser version
· operating system
· referrer URL, i.e. the address of the website from which you access our website
· time of the server request
· IP address
The IP address is stored for a maximum of 9 weeks in anonymised form (by deleting the last digits). This means that the truncated IP address can no longer be linked to a specific Internet access or end device. The truncated IP address is deleted after 9 weeks.
This data is processed to analyse the use of the website and to prevent and prosecute unlawful use. The legal basis for processing is Article 6(1)(f) GDPR (protection of legitimate interests). Our legitimate interests are the optimisation of our information offering and our services, the guarantee of system security and the assertion and enforcement of claims.
2.2 Cookies and similar technologies
Our websites use cookies. Cookies are small text files that the browser stores on your end device. Cookies help us to make our website more user-friendly, effective and secure.
‘Session cookies’ are automatically deleted at the end of your browser session. ‘Persistent’ cookies remain on your end device until you actively delete them or the intended period of validity has expired; such cookies are used to recognise you when you return to a website.
Many browsers can be configured so that cookies are deactivated, or cookies are deleted automatically when the browser is closed. Under certain circumstances, this may limit the functionality of a website.
Placing ‘essential’ cookies (cookies which are necessary for providing a website and certain functions that you require) is based on Section 25 (2)(2) Telekommunikation-Digitale-Dienste-Datenschutz-Gesetz (TDDDG), Article 6(1)(f) GDPR. As the operator of the website, we have a legitimate interest to store cookies for the purpose of providing our services smoothly and free of technical errors.
For the use of other, i.e. ‘non-essential’, cookies (e.g. for analysis and marketing purposes) and certain other technologies, we obtain your express consent via the Consent Manager (see 2.2.1). The legal basis for this is Section 25(1) TDDDG, Article 6(1)(a) GDPR (consent).
2.2.1 Consent Manager
When you visit one of our websites, you will immediately see the Consent Manager (a ‘cookie banner’). The Consent Manager asks you to choose your cookie preferences, i.e. whether or not you consent to the use of certain cookies.
We place a permanent consent; this cookie stores the information that the Consent Manager has been displayed to you and which consents you have given. This cookie remains on your end device; as a result, the Consent Manager will no longer be displayed when you revisit the website. The legal basis for this is Section 25(2)(2) TDDDG, Article 6(1)(f) GDPR (our legitimate interest: providing the website).
You can withdraw the consent that you have given via the Consent Manager at any time by accessing the Consent Manager via the ‘Cookie settings’ link and updating your preferences.
2.2.2 Google Analytics
If you have given your consent (see 2.2.1), our websites use Google Analytics, a web analytics service provided by Google. Google is a group of companies, consisting of Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland (the provider of the service), Google LLC, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA (the parent company) and other affiliated companies of Google LLC. We have concluded data processing agreement with Google Ireland Ltd. in accordance with Article 28 GDPR.
We use Google Analytics with deactivated ‘user ID function’. According to Google, this means that a user’s activity is not collected and assigned to a user ID. According to Google, your IP address is also immediately truncated and anonymised by Google within the European Union. According to Google, non-anonymised IP addresses are transmitted to the US only in exceptional cases. According to Google, the IP address transmitted by your browser as part of Google Analytics is also not combined with other Google data.
During your visit to the website, your user activity is recorded in the form of ‘events’. Such events can be
• page views
• first visit to the website
• start of the session
• visited websites
• ‘click path’ (your interaction with the website)
• scrolls (when a user scrolls to the end of the page (90%))
• clicks on external links
• internal search queries
• interaction with videos
• file downloads
• viewed / clicked adverts
• language settings
The following information is also recorded:
• your approximate location (region)
• time and date of the visit
• your IP address (in truncated form)
• technical information on your browser and the end devices you use (e.g. language settings, screen resolution)
• your internet provider
• the referrer URL (via which website or advertisement you have accessed the website)
The information on your use of the website collected by the cookies, which cannot be linked to a specific person, as the IP address has been anonymised, is usually transmitted to a Google server in the USA and stored there. Google will use this information on our behalf to analyse the use of the website. The data that is transmitted in connection with cookies is automatically deleted after two months. The maximum lifespan of Google Analytics cookies is two years. Data whose retention period has been reached is automatically deleted once a month.
The legal basis for data processing is Section 25(2)(2) TDDDG, Article 6(1)(a) GDPR (consent). You can withdraw your consent at any time (see 2.2.1).
2.2.3 YouTube player
If you have given your consent (see 2.2.1), our websites use the embedded YouTube player to integrate and display video content. The provider is Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland.
When you access a page with an embedded YouTube player, a connection to YouTube/Google servers is established. This means that YouTube/Google learns which of our pages you have visited. YouTube/Google can link your surfing activity directly to your personal profile if you are logged into your Google account. You can prevent this by logging out before you visit our website.
The legal basis is Article 6 (1)(a) GDPR. You can withdraw your consent at any time (see 2.2.1).
2.2.4 Google Fonts
If you have given your consent (see 2.2.1), our websites use external fonts provided by Google (Google Fonts). Google Fonts is a service provided by Google LLC, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA. The font files are downloaded from a Google server in the USA. This means that your IP address is transmitted to Google, and Google learns which website you have visited. The IP address will not be combined with other data by Google.
The legal basis is Article 6(a)(a) GDPR. You can withdraw your consent at any time (see 2.2.1).
2.2.5 Meta pixel
If you have given your consent (see 2.2.1), we use Meta Pixel. Meta Pixel is a service provided by Meta Platforms Inc, 1 Hacker Way, Menlo Park, CA 94025, USA. We have concluded data processing agreement with Meta in accordance with Article 28 GDPR.
We would like to know the outcome of our activities (posts, advertisements) on the social media networks Facebook and Instagram. For this purpose, we receive data from Meta which is purely statistical data and not linked to specific persons. This enables us to determine, for market research purposes, how effective advertisements are. Whenever a Meta Pixel on our website is accessed, Meta can recognise whether an advertisement on Facebook or Instagram was successful, e.g. whether it resulted in an online purchase (‘conversion’). This allows us to track conversions, optimise advertisements and create target groups for our advertising on Facebook. For this purpose, Meta places a cookie on the user’s device, which stores what content the user has viewed on our website. When you visit our pages, a direct connection is established between your browser and the Meta server via the pixel. Meta receives the information from your browser that our website has been accessed from your end device. If you are a Facebook or Instagram user, this allows Meta to link your visit to our website with your user account and the cookie can be recognised in the Facebook/Instagram network. If the cookie is recognised, Meta can display personalised advertising to the user on Facebook and Instagram that corresponds to the content (or the interests derived from it) that the user has viewed on our website.
The legal basis is Section 25(2)(2) TDDDG, Article 6(1)(a) GDPR (consent). You can withdraw your consent at any time (see 2.2.1).
2.3 Recipients of personal data; transfer of personal data to third countries
If you have given your consent for one or more of the Google or Meta services mentioned in section 2.2 , personal data may be transmitted to Google LLC or Meta Platforms Inc.
Google LLC and Meta Platforms Inc are based in the USA, i.e. in a third country outside the territorial scope of apllication of the GDPR. Both companies are certified under the EU-U.S. Data Privacy Framework (DPF). When personal data is transferred to the USA in connection with Google or Meta services, this is permitted according to the European Commission's adequacy decision relating the DPF pursuant to Article 45(1)(a) GDPR.
To protect the data that you transmit via a website (e.g. when you use a contact form), we use SSL or TLS encryption. This prevents third parties from intercepting the transmitted data. You can recognise an encrypted connection by the character string ‘https://’ in the address bar of your browser and/or by the lock symbol in the address bar.
3. Processing of personal data when you use our apps
3.1 Using an app on your end device
We do not process any personal data on you when you use an app on your end device (smartphone or tablet).
All data generated during use, e.g. the current status of a game, remains on your end device.
For the "AT Circles" app, the following applies additionally:
The app uses the Microsoft Azure PlayFab platform. The provider is PlayFab, Inc., 1 Microsoft Way, Redmond, WA 98052 USA. We have concluded a data processing agreement with PlayFab as our service provider in accordance with Art. 28 GDPR.
We have also agreed on the so-called EU Standard Contractual Clauses with PlayFab. This provides an "appropriate safeguard" under which the transfer of personal data to the "third country" USA (a third country is any country outside the scope of the GDPR, i.e., the EU and EEA [Norway, Iceland, Liechtenstein]) is permissible in accordance with Art. 46 para. 2 letter c GDPR. The Standard Contractual Clauses can be found at https://playfab.com/privacy-terms/.
When you use the app, PlayFab may collect the following data on our behalf:
Device Information:
Operating system
Hardware type (device model)
Network status (Wi-Fi or mobile data)
User Information:
Player ID (PlayFab player identifier)
Gamertags or username
First login (date)
Last login (date)
Game Statistics:
Points and ranking on the leaderboard
Level and progress data
Connection Data:
IP address
Location data (based on IP address, to understand the regional distribution of players)
Device and Usage Analytics:
Error reports and crash data
Leaderboard-specific Data:
Username or alias on the leaderboard
Points, high scores, ranks, and other rating metrics
The legal basis is Art. 6 para. 1 letter b (performance of a contract).
3.2 In-app purchases
If you purchase content offered by us within an app (‘in-app purchase’), the purchase, including payment, is processed directly in the respective Apple or Google app store. In the case of an iOS app, the price is debited from your iTunes balance; in the case of an Android app, the payment method you have stored in the Google Play Store is debited.
4. Processing of personal data when you use our social media profiles
4.1 Facebook, Instagram
4.1.1 Joint controllership
With regard to our social media profiles on Facebook and Instagram, we (funline Media GmbH; for contact details see Section 1 above) and Meta Platforms Ireland Limited, Merrion Road, Dublin 4, D04 X2K5, Ireland, the provider of the social networks Facebook and Instagram, are “joint controllers” (as defined in the GDPR).
4.1.2 Applicability of the above information
With regard to our independent controllership for the processing of personal data carried out by ourselves, the information in sections 1, 5, 6 and 7 applies. For the transfer of personal data to Meta Platforms Inc ("Meta"), please refer to section 2.3.
4.1.3 Processing of personal data
4.1.3.1 Processing by funline Media GmbH
We use Facebook and Instagram for public relations and to market our services. For this purpose, we process the data which users of the social networks themselves provide (e.g. usernames, comments).
The legal basis for this processing is the pursuit of legitimate interests, Article 6 (1) (f) GDPR, namely the marketing of our products and services, including on social media. We ourselves do not share any of this personal data with third parties. The data will be deleted, according to the options provided to us by the social networks, as soon as it is no longer required for the aforementioned purpose.
4.1.3.2 Processing by Meta
To learn which personal data Meta processes when you visit Facebook or Instagram, or our profiles on Facebook or Instagram, what the legal basis of this processing is, whether this data is also processed outside the EU and how long this data is stored by Meta, please refer to Meta's privacy policy (https://privacycenter.instagram.com/policy).
Please note that Meta collects a range of data when you visit our profiles on Facebook or Instagram, including the IP address of the end device that you are using. Meta processes this data to provide us with statistical data ("Insights") on how our social media profiles are used. Such aggregated data does not relate to identifiable persons.
Please refer to Meta's privacy policy to find out how Meta uses personal data stemming from visits to Facebook/Instagram profiles for its own purposes, to what extent activities are related to individual users, how long Meta stores this data and whether data from a visit to a profile is shared with third parties.
In the agreement on joint controllership pursuant to Article 26 GDPR that we have concluded with Meta, Meta as the provider of Facebook and Instagram acknowledges the joint controllership with regard to “Insights” data and assumes the obligations under data protection law to inform data subjects, to ensure data security and to report any data breaches. In accordance with this agreement, Meta is the primary point of contact for data subjects exercising their rights; Meta has direct access to the personal data and can provide access to personal data or take other measures.
4.2 YouTube
We use the video platform YouTube. We and the provider of YouTube, Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland, a subsidiary of Google LLC, 1600 Amphitheatre Parkway, Mountain View, CA 94043-1351, U.S.A., are joint controllers (as defined in the GDPR).
4.2.1 Applicability of the above information
With regard to our independent controllership for the processing of personal data carried out by ourselves, the information in sections 1, 5, 6 and 7 applies. For the transfer of personal data to Google LLC (“Google”), please refer to section 2.3.
4.2.2 Processing of personal data
4.2.2.1 Processing by funline Media GmbH
We use YouTube for public relations and to market our services. For this purpose, we process the data which users of YouTube themselves provide (e.g. usernames, comments).
The legal basis for this processing is the pursuit of legitimate interests, Article 6 (1) (f) GDPR, namely the marketing of our products and services, including on social media. We ourselves do not share any of this personal data with third parties. The data will be deleted, according to the options provided to us by YouTube, as soon as it is no longer required for the aforementioned purpose.
4.2.2.2 Processing by Google
Every time a user accesses our YouTube channel, Google processes personal data. Please refer to Google's privacy policy (https://policies.google.com/privacy?hl=en) to find out which data is processed, the legal basis for this, whether this data is also processed outside the European Union and how long this data is stored by Google.
Please note that Google collects and processes a range of data when you visit our YouTube channel, including the IP address of the end device you are using. Google processes this data to provide us with statistical data ("Insights") on how our YouTube channel is used. Such aggregated data does not relate to identifiable persons.
Please refer to Google's privacy policy to find out how Google uses the data stemming from visits to YouTube channels for its own purposes, to what extent activities are related to individual users, how long Google stores this data and whether data stemming from a visit to a YouTube channel is shared with third parties.
Google has direct access to the personal data and can, for example, provide access to personal data or take other measures.
4.3 X (formerly Twitter)
We use the microblogging service X. The provider of the platform and controller (as defined in the GDPR) is Twitter International Unlimited Company, One Cumberland Place, Fenian Street, Dublin 2, D02 AX07, Ireland, a subsidiary of X Corp, 865 FM 1209, Building 2, Bastrop, TX 78602, USA.
With regard to our responsibility for the processing of personal data carried out by ourselves, the information in sections 1, 5, 6 and 7 also applies to our X profile. We ourselves as the owner of a profile on X do not process any other data the context of your use of X.
X Corp. is based in the USA, a third country outside the territorial scope of application of the GDPR. The company is certified under the EU-U.S. Data Privacy Framework (DPF). When personal data is transferred to X Corp., this is permitted on the basis of the European Commission's adequacy decision on the DPF pursuant to Article 45 (1) (a) GDPR.
Please note that you use X and its functions at your own risk. This applies in particular to the use of the interactive functions (e.g. “Share”).
The data collected relating to you when you use X is processed by Twitter and may be transferred to countries outside the European Union. This includes your IP address, the application you are using, information about the device you are using (including device ID and application ID), information about websites accessed, your location and your mobile phone provider. This data will be connected to your X profile. We have no influence on the nature and scope of the data processed by X, the purposes of processing and the disclosure of data to third parties. Information about which data Twitter processes and for what purposes it is used can be found in X's privacy policy at (https://twitter.com/privacy?lang=de).
You may request information via the X data protection form or archive requests (https://support.twitter.com/forms/privacy; https://help.twitter.com/de/managing-your-account/how-to-download-your-twitter-archive).
You have the option of restricting the processing of your data in the settings of your X profile. On mobile devices, you can also restrict X's access to contact and calendar data, photos, location data, etc. in the settings options of the device (depending on the operating system). Further information can be found at https://help.x.com/de/safety-and-security/x-privacy-settings.
4.4 Bluesky
We use the microblogging service Bluesky. Bluesky is a decentralised service consisting of a large number of servers (“Bluesky instances”) operated by private individuals or organisations. Our account is located in the Bluesky instance “bsky.social”. The provider and controller (as defined in the GDPR) is Bluesky PBLLC, 113 Cherry St # 24821, Seattle Washington 98104-2205, USA.
With regard to our responsibility for the processing of personal data carried out by ourselves, the information in sections 1, 5, 6 and 7 also applies to our Bluesky profile. We ourselves as the owner of a profile on Bluesky do not process any other data in the context of your use of Bluesky.
Please note that you use Bluesky and its functions on your own responsibility, also with regard to the fact that Bluesky is based in the USA, a third country outside the territorial scope of application of the GDPR. This applies in particular to the use of the interactive functions (e.g. “share”).
The data collected relating to you when you use Bluesky is processed by Bluesky in the USA. We have no influence on the nature and scope of the data processed by Bluesky, the purposes of processing and the disclosure of data to third parties. Information about which data is processed by Bluesky and for what purposes it is used can be found in Bluesky's privacy policy (https://blueskyweb.xyz/support/privacy-policy).
4.5 Pinterest
We use Pinterest. The service providers and joint controllers (as defined in the GDPR) are Pinterest Europe Ltd., Palmerston House, 2nd Floor, Fenian Street, Dublin 2, Ireland, and Pinterest, Inc., 651 Brannan St., San Francisco, CA 94107, USA. Pinterest Europe Ltd. is responsible for compliance with the essential obligations under the GDPR, including the rights of data subjects.
With regard to our responsibility for the processing of personal data carried out by ourselves, the information in sections 1, 5, 6 and 7 also applies to our Pinterest profile. We ourselves as the owner of a profile on Pinterest do not process any other data in the context of your use of Bluesky.
Please note that you use Pinterest and its functions on your own responsibility, also with regard to the fact that Pinterest Inc. is based in the USA, a third country outside the territorial scope of application of the GDPR. This applies in particular to the use of the interactive functions (e.g. “share”).
The data collected relating to you when you use Pinterest is processed by Pinterest Inc. in the USA. We have no influence on the nature and scope of the data processed by Pinterest, the purposes of processing and the disclosure of data to third parties. Information about which data is processed by Pinterest and for what purposes it is used can be found in Pinterest's privacy policy (https://policy.pinterest.com/privacy-policy).
5. Processing of personal data that you provide to us
5.1 Contact with us
When you contact us (via a contact form, by e-mail or in any other way), we process the data you provide to process your enquiry.
The legal basis is either Article 6(1)(b) GDPR (performance of a contract: in the case of a support request by a customer; steps prior to entering into a contract: if you request an offer or information material from us) or Article 6 para. 1 letter f GDPR (pursuit of legitimate interests, namely marketing our products and services: in the case of other enquiries).
5.2 E-mail newsletter
We need your email address to send you our newsletter; other details such as your name and title are optional.
To verify your email address, we will send you a confirmation email asking you to confirm your consent by activating a confirmation link (‘double opt-in’ procedure). If we do not receive such confirmation, we will no longer process your email address and will delete it within seven days. The legal basis is Article 6(1)(f) GDPR (legitimate interest: authentication of the data subject and documentation of consent).
The data you provide when registering will be processed on the basis of your consent in accordance with Article 6(1)(a) GDPR. You can withdraw your consent at any time; the easiest way is to use the unsubscribe link contained in every newsletter message.
6. Period of storage
Unless stated otherwise above, we store personal data as long as the processing is necessary for one of the purposes mentioned above.
7. Your rights
You have the following rights, subject to the respective legal requirements:
· You can withdraw consent at any time (Article 7(3) GDPR).
· You have the right to obtain information on the personal data concerning you that we process (Article 15 GDPR).
· You have the right to request the rectification of inaccurate data (Article 16 GDPR).
· You have the right to request the erasure (Article 17) or restriction of processing (Article 18 GDPR) of personal data that is no longer necessary.
· You have the right to data portability (Article 20 GDPR).
· If you consider that the processing of your data infringes data protection laws, you have the right to lodge a complaint with a supervisory authority (Article 77 GDPR). The local supervisory authority with jurisdiction over us is: Bayerisches Landesamt für Datenschutzaufsicht, Promenade 18, 91522 Ansbach, Germany (https://www.lda.bayern.de/).
8. Right to object
You can object to the processing of your data for direct marketing purposes at any time (Article 21(2) GDPR). On grounds relating to your particular situation, you can also object to other processing which is based on the pursuit of legitimate interests at any time (Article 21(1) GDPR).
Lazuli is a funline media GmbH production, sponsored by the FFF Bayern.
The games have been developed with the help of children, parents, educational specialists, psychologists, and teachers.
We’d like to thank you and all the children who kept testing it.
