PRIVACY POLICY

Welcome to Cold Comfort.

TLDR – Policy Overview

This Policy explains how we may Process your information. This Policy may be amended or updated from time to time, so please check it regularly for updates.

This Privacy Policy sets forth our policy with respect to information that is collected from visitors to the site and users of the website and/or services. This privacy notice tells you about the information we collect from you when you sign up to receive our newsletter or create an account on our website. In collecting this information, Gamma Minus is acting as a data controller and, by law, is required to provide you with information about us, about why and how we use your data, and about the rights you have over your data.


Who are we?

Our address is Schulze-Delitzsch-Strasse 24, 33100 Paderborn, Germany. You can contact us by mail at the above address, by email [email protected] or by telephone on +49 1512 756 3230.

The terms “you,” “your,” and “yours” refer to the customers using our website and services. We are committed to safeguarding the privacy of our website visitors; this policy sets out how we will carefully treat your personal information.

Occasionally, at our discretion, we may include or offer third party products or services on our website. This Privacy Policy applies only to our website and services. These may contain links to other web sites not operated or controlled by us (the “Third Party Sites”). These third party sites have separate and independent privacy policies. We therefore have no responsibility or liability for the content and activities of these linked sites. We suggest contacting those sites directly for information on their privacy policies.

What personal data do we collect?

TLDR – Categories of Information

We may process: personal details (e.g., name); demographic data (e.g., age); contact details (e.g., address); records of your consents; purchase details; information about interactions with our content or advertising; and any views or opinions provided to us. We may also process information about the use of our services (e.g., the type of device you are using, the internet service provider, etc.), including interactions with content and advertising on the services.

When you interact with us through the website, we may collect information from you, as further described below.

(a) Information you voluntarily provide to us:

We collect information from you when you voluntarily provide such information, such as:

  • information that you contractually provide to us for the purpose of registering an account on our website for access to our services
  • information that you explicitly provide to us for the purpose of subscribing to our email notifications and/or newsletters;
  • any other information that you choose to send to us

Information we collect may include but not be limited to username, email address, and any messages, images or other content you send via the comment feature.

(b) Information we collect automatically:

When you interact with us through the website, we receive and store certain information such as:

  • information about your computer and about your visits to and use of this website (including your IP address, geographical location, browser type and version, operating system, referral source, length of visit, page views, and website navigation);
  • information relating to any transactions carried out between you and us on or in relation to this website, including information relating to any purchases you may make of our goods or services;

We may store this information or such information may be included in databases. The website may use this information and combine it with other information to track, p.e., the total number of visitors to our website, the number of messages users have sent, as well as the sites which refer visitors to our website

(c) Aggregated Information:

In an ongoing effort to better understand and serve the users of the website, we may conduct research on our customer demographics, interests and behavior based on the information collected. This research may be compiled and analyzed on an aggregate basis, and we may share this aggregate data with our affiliates, agents and business partners. We may also disclose aggregated user statistics in order to describe our services to current and prospective business partners, and to other third parties for other lawful purposes.

(d) Info through other Services:

You may give us permission to collect your information in other services. For example, you may connect a social networking service (“SNS”) such as Facebook or Twitter, or similar accounts such as Steam, to your account. When you do this, it allows us to obtain information from those accounts (for example, your friends or contacts).

(e) Cookies (NomNom):

We employ cookies and similar technologies to keep track of your local computer’s settings such as which account you have logged into and notification settings. Read more in our Cookie Policy.

We may use third party web site analytic tools such as Google Analytics on our website that employ cookies to collect certain information concerning your use of our Services. However, you can disable cookies by changing your browser settings. Further information about the procedure to follow in order to disable cookies can be found on your Internet browser provider’s website via your help screen.

(f) Advertisements:

We may use third-party advertising companies to serve ads when you visit our website. These companies may use information about your visits to this and other websites in order to provide advertisements about goods and services of interest to you. We may allow third-party companies to serve ads and/or collect certain anonymous information when you visit our web site. These companies may use non-personally identifiable information (e.g., click stream information, browser type, time and date, subject of advertisements clicked or scrolled over) during your visits to this and other websites in order to provide advertisements about goods and services likely to be of greater interest to you. These companies typically use a cookie or third party web beacon to collect this information. To learn more about this behavioral advertising practice or to opt-out of this type of advertising, click here.

If you do not wish to receive personalized advertising that is delivered by third parties outside of the website, you may be able to exercise that choice through opt-out programs that are administered by third parties, including the Network Advertising Initiative (NAI), the Digital Advertising Alliance (DAA).

How We Collect or Create Information.

TLDR – Collection and Creation of Information

We may collect or obtain user information: directly (e.g., contacting us); in the course of our relationship (e.g., making purchases); personal Information is made public (e.g., making a public post about us on social media); by downloading, installing, or using any of our services; visiting our website; by registering to use any part of the website or services; or by interacting with any third party content or advertising on the website. We may also receive user information from third parties (e.g., social network sites). We may also create user information, such as records of interactions with us. Gamma Minus is not responsible for personal information volunteered in public areas of the website (e.g., forum). This policy does not cover the practices of third parties who may provide information about to Gamma Minus.

Why do we collect this information?

TLDR – Purposes for Which We May Process Your Information

We may process user information for the following purposes: providing services; communicating; providing advertising; analyzing engagement with our audience; observing user engagement and purchase activity across the website; marketing our services and offerings to current and prospective customers; managing our IT systems; financial management; conducting surveys; ensuring the security of our systems; conducting investigations where necessary; compliance with applicable law; and improving our services.

What do we do with your data?

We use the information you provide in a manner that is consistent with this Privacy Policy. If you provide information for a certain reason, we may use the information in connection with the reason for which it was provided. For instance, if you contact us by email, we will use the information you provide to answer your question or resolve your problem. Also, if you provide information in order to obtain access to the website or our services, we will use your information to provide you with access to these and to monitor your use of them.

Your data will be used to:

  • personalize your experience (your information helps us to better respond to your individual needs)
  • To improve our website (we continually strive to improve our website offerings based on the information and feedback we receive from you)
  • To improve customer service (your information helps us to more effectively respond to your customer service requests and support needs)
  • To administer a contest, promotion, survey or other site feature
  • To send periodic emails
  • The email address you provide may be used to send you information, respond to inquiries, and/or other requests or questions.

Gamma Minus and its affiliates may use this information to contact you in the future to tell you about services we believe will be of interest to you. If we do so, each marketing communication we send you will contain instructions permitting you to “opt-out” of receiving future marketing communications. In addition, if at any time you wish not to receive any future marketing communications or you wish to have your name deleted from our mailing lists, please contact us.

(a) Creating an account

When creating an account we will use this information, in conjunction with a password you choose, to secure our services to you.

We may use your personal information to:

  • administer the website;
  • improve your browsing experience by personalizing the website;
  • enable your use of the services available on the website;
  • supply to you services purchased via the website;
  • send statements and invoices to you, and collect payments from you;
  • send you general (non-marketing) commercial communications;
  • invite you to review the website using a trusted third-party service;
  • verify that you satisfy any age restrictions applicable to our products

(b) Subscribing to our newsletter

We will use your personal information to send you personalized emails containing information about our own products and occasionally related services, which often include special offers. We will only send you our newsletter for as long as you continue to consent.

Data Security.

TLDR – Data Security

We implement appropriate technical and organizational security measures to protect user information. Please ensure that any personal information that sent to us is sent securely.

We have implemented appropriate technical and organizational security measures designed to protect user information against accidental or unlawful destruction, loss, alteration, unauthorized disclosure, unauthorized access, and other unlawful or unauthorized forms of processing, in accordance with applicable law. However, we cannot guarantee there will not be a breach, and we are not responsible for any breach of security or for the actions of any third parties.

Because the internet is an open system, the transmission of information via the internet is not completely secure. Although we will implement reasonable measures to protect your information, we cannot guarantee the security of your data transmitted to us using the internet. Any such transmission is at your own risk and you are responsible for ensuring that any personal information that you send to us are sent securely.

We take reasonable steps to protect the information provided via the website from loss, misuse, unauthorized access, disclosure, alteration, or destruction. However, no Internet or email transmission is ever fully secure or error free. Therefore, you should take special care in deciding what information you send to us via email. Please keep this in mind when disclosing any information via the Internet.

Your information is securely stored on a database and is only shared with the third parties required to enable us to operate our website and offer you specific services.

The company is based in Germany. No matter where you are located, you consent to the processing and transferring of your information in and to Germany and other countries. The laws of Germany and other countries governing data collection and use may not be as comprehensive or protective as the laws of the country where you live.

Your information is stored both inside and outside of Germany. Any data stored outside of Germany is entrusted to companies which offer the same GDPR level of security.

We will not use the information to make any automated decisions that might affect you.

Disclosure of your data.

TLDR – Disclosure of User Information

We may disclose user information to: legal and regulatory authorities; our external advisors; parties who process user information on our behalf (“Processors”); any party as necessary in connection with legal proceedings; any party as necessary for investigating, detecting or preventing criminal offenses; any purchaser of our business; and any third party providers of advertising, plugins or content used on the website.

Gamma Minus is not in the business of selling your information. We consider this information to be a vital part of our relationship with you. There are, however, certain circumstances in which we may share your information with certain third parties when we believe release is appropriate to comply with the law, enforce our site policies, or protect ours or others rights, property, or safety. However, non-personally identifiable visitor information may be provided to other parties for marketing, advertising, or other uses.

Unsolicited Information.

You may provide us with ideas for new products or modifications to existing products, and other unsolicited submissions (collectively, “Unsolicited Information”). All unsolicited information shall be deemed to be non-confidential and we shall be free to reproduce, use, disclose, and distribute such unsolicited information to others without limitation or attribution. Please note that Gamma Minus is not responsible for the information you volunteer about yourself in the discussions in certain public areas of the website or information that you choose to make public in your member profile or other areas of the website that allow users to upload or post content. We discourage users from posting such personal information in this fashion

Sensitive Personal Information.

TLDR – Sensitive Personal Information

We do not seek to collect or otherwise process sensitive personal information. Where we need to process sensitive personal information for a legitimate purpose, we do so in accordance with applicable law. The services are not intended for use by children.

We do not collect or otherwise process personal information about race or ethnicity, political opinions, religious or philosophical beliefs, trade union membership, physical or mental health, sexual life, any actual or alleged criminal offenses or penalties, or any other information that may be deemed to be sensitive under GDPR (collectively, “Sensitive Personal Information”) in the ordinary course of our business. Where it becomes necessary to process sensitive personal information under GDPR, we would rely on one of the following legal bases:

  • Compliance with applicable law: We may process sensitive personal information where the processing is required or permitted by applicable law;
  • Detection and prevention of crime: We may process sensitive personal information where the processing is necessary for the detection or prevention of crime (including the prevention of fraud);
  • Establishment, exercise or defense of legal rights: We may process sensitive personal information where the processing is necessary for the establishment, exercise or defense of legal rights; or
  • Consent: We may process sensitive personal information where we have, in accordance with applicable law, obtained prior, express consent to processing sensitive personal information.

Children.

Our services are not intended for use by children, especially those under 13. No one under the age of 13 should provide any personal information. If it is discovered that we have collected personal information from someone under 13, we will delete that information immediately.

If you are a parent or guardian of a child under the age of 13 and believe he or she has disclosed personal information to us please contact us via the channels stated.

How long do we keep your information?

TLDR – Data Retention

We take every reasonable step to ensure that your User Information is only retained for as long as they are needed.

Your information is kept on our systems for as long as you have an account on our system and as long as it may be relevant to the purposes identified herein. Data may persist in copies made for backup and business continuity purposes for additional time.

To dispose of personal data, we may anonymize it, delete it or take other appropriate steps.

Newsletter subscriptions are kept as long as you continue to consent to receive our newsletter.

What is the Lawful Basis for Processing Personal Information?

TLDR – Lawful Basis for Processing User Information

We may process user information where: we already have consent; the processing is necessary for a contract; the processing is required by applicable law; the processing is necessary to protect the vital interests of any individual; or where we have a valid legitimate interest in the processing.

In processing user information in connection with the purposes set out in this Policy, we may rely on one or more of the following legal bases, depending on the circumstances:

  • Consent: We may process user information where we have obtained prior, express consent to the processing (this legal basis is only used in relation to processing that is entirely voluntary – it is not used for processing that is necessary or obligatory in any way);
  • Contractual necessity: We may process user information where the processing is necessary in connection with any contract that you may enter into with us;
  • Compliance with applicable law: We may process user information where the processing is required by applicable law;
  • Vital interests: We may process user information where the processing is necessary to protect the vital interests of any individual; or
  • Legitimate interests: We may process user information where we have a legitimate interest in carrying out the processing for the purpose of managing, operating or promoting our business, and that legitimate interest is not overridden by your interests, fundamental rights, or freedoms.


Your rights over your information.

TLDR– What Can I Do to Control My Information?

You can directly take steps to change your preferences for newsletters and online behavioral advertising as outlined in this section.

EU residents may have certain rights including: to not provide personal information; access to your personal information; request rectification of inaccuracies; requesting the erasure, or restriction of processing, of personal information; object to the processing of personal information; personal information transferred to another controller; withdrawing consent; and to lodge complaints with supervisory authorities. We may require proof of or need to verify your identity before we can give effect to these rights.

By law, you can ask us what information we hold about you, and you can ask us to correct any inaccuracies.

You can also ask for it to be erased, you can ask for us to give you a copy of the information and you can request that we stop processing your information and also update certain information by accessing your profile via “Settings”.

(a) How to ask us to stop processing your account information.

If you wish for us to stop processing account information then the simplest way to do this is to request an account cancellation. This will remove access to your account and will flag the account and its associated data to be removed after retention.

(b) How to ask us to stop processing your email subscription information.

You can withdraw your consent to receive our email subscription at any time, an ‘Unsubscribe’ button is included at the end of every subscription email that we send to you. Simply click on this link and follow the instructions.

Additionally you can email us or write to us using the contact details above.

Terms of Service.

Please also visit our Terms of Service section, establishing the use, disclaimers, and limitations of liability governing the use of our website.

Changes to our Privacy Policy.

We reserve the right to update or modify this Privacy Policy at any time and from time to time without prior notice. Please review this policy periodically, and especially before you provide any information. Your continued use of the Services after any changes or revisions to this Privacy Policy shall indicate your agreement with the terms of such revised Privacy Policy.