Impressum & Privacy Policy
Impressum & Data Controller
Paul Schwandes, C/O www.impressum-ohne-adresse.de, Wernher-von-Braun-Str. 5-7, 69214 Eppelheim.
(Impressum ohne Adresse wird zur Verfügung gestellt von Antavi IT Solutions GmbH.)
Email: paul@schwandes.de / Phone: (+49) 01577-4465389.
Your Rights: You have the right to request access to, rectification of, erasure of, restriction of, or portability of your data, and to withdraw any given consent at any time via email. You may also lodge a complaint with the supervisory authority. YOU HAVE THE RIGHT TO OBJECT AT ANY TIME TO THE PROCESSING OF YOUR DATA BASED ON LEGITIMATE INTERESTS FOR REASONS ARISING FROM YOUR PARTICULAR SITUATION.
Automated Decision-Making: I do not use automated decision-making or profiling as defined in Art. 22 GDPR.
Contacting Me: If you reach out to me, your data is processed depending on your request.
- GDPR Rights Requests: Processed to fulfill my statutory legal obligations and retained for 3 years to demonstrate compliance.
- General Inquiries: Processed based on my legitimate interest in resolving your query and deleted once resolved.
Website Hosting & Technical Data: I host this site with netcup GmbH under a Data Processing Agreement. Traffic to this site is SSL/TLS encrypted. To maintain website security, your connection and browser metadata are stored in server log files for 7 days based on my legitimate interest in secure operations.
Cookies: I do not use cookies for general visitors. Out of technical necessity (§ 25(2) TDDDG), an internal administrative page may set a host_password cookie valid for up to 1 year which allows downloading replays submitted via my website.
Submissions, Show Broadcasts & Third Parties: When you submit a run, I process your comments, metadata, and replay files to execute the Submission Terms. Your submission data is routed by my server to Google Ireland Ltd./Google LLC (forms) and Discord Netherlands BV/Discord Inc (file storage). Once integrated, submissions (including any gameplay, replay data, and usernames contained within them) are publicly broadcasted and archived based on my legitimate interest in preserving the show’s public archive for the duration of the Touhou Replay Showcase project.
If another user’s submission contains your username or gameplay data, I process this data as part of the public replay files. I do not notify you directly, as lawfully verifying identities based on replay names would involve disproportionate effort (Art. 14(5)(b) GDPR).
Necessity of Providing Data: Providing connection and browser metadata is technically required to load the site. Providing request data is necessary to receive a response. Providing submission data is a requirement to enter into the Submission Terms. Without this data, these actions are impossible.
US Data Transfers (Art. 13(1)(f) GDPR): Google and Discord process data in the US under the active EU-US Data Privacy Framework adequacy decision. Additionally, both providers protect these transfers through standard Data Processing Addenda incorporating the EU Standard Contractual Clauses (SCCs). These standard terms are made publicly available by the providers:
- Google’s data protection terms can be viewed at Google Business Safety.
- Discord’s privacy commitments can be viewed in the Discord Privacy Policy.
If these safeguards or the adequacy decision are invalidated or inapplicable in the future, I rely on the following fallback mechanisms under Article 49(1) GDPR:
- Contract performance: Submission transfers are strictly necessary to perform the Submission Terms (Art. 49(1)(b) GDPR).
- Explicit consent: For external iframes (such as the schedule viewer), you provide explicit consent to the transfer (Art. 49(1)(a) GDPR) by actively clicking the button to load the content, acknowledging the potential risk of US authority access.