Privacy Agreement KTG App / Location-Based Game App


1. Object of this data protection statement

In this data protection statement, we, KTG Karlsruhe Tourismus GmbH (hereinafter referred to as “KTG”), wish to inform you about which personal data (hereinafter referred to as the “Data”) will be collected for the use of the KTG App (hereinafter referred to as the “App”, the “KTG App”, the "game App" or "treasure hunt App") and how this Data will be processed or used, as well as which technical and organizational protection measures will be taken. You can also download this data protection statement as a PDF here..

2. Controller/service provider

KTG processes personal data in compliance with the General Data Protection Regulation of the European Union (EU GDPR) as well as the German Data Protection Act (BDSG) and the German Telemedia Act (TMG). The responsible office is KTG Karlsruhe Tourismus GmbH, Kaiserstrasse 72-74, 76133 Karlsruhe, Germany. See also the imprint of the app.

Please send questions or comments regarding this data protection statement or regarding data protection in general to the following email address: info@karlsruhe-tourismus.de

3. Data collection and use in connection with the download of the app from the app store

Which data will be collected when downloading the treasure hunt app from an app store (google Play-Store and iOS App-Store) and the purposes for which it is used can be found in the respective data protection information of the app store. This information usually includes your user name, email address and customer number associated with the account you have registered with the app store, the date and time of the download, and the individual identification number of your device. The app store processes this data if this is required in order to download the App to your device.

We will not receive any notice from the app store in this regard.

4. Data collection and use in connection with registration or the use of accounts without login

You can use the downloaded KTG App either without logging in or by registering and creating a user account.

a. Account without registration

If you choose to use an account without registering, a random, non-existent email address will be generated and saved as your user account. However, you will unfortunately not be able to retrieve your progress in the game after logging out of the App. This is only possible if you register and create a personal user account. Your number of points is limited to 3,000 if you do not use a personal user account to log in to the App. Beyond this limit, you will no longer be able to play any tasks. If you wish to continue playing, you must register.

The option of an account without registration is only possible once prior to your first login. Later, this option will no longer be available.

b. Registration/personal user account

If you want to use the KTG App via your own personal user account, you must first register in the App with your email address, a password of your choosing, and a user name (the “Login Information”). You are free to choose any user name you want but it must not be your real name.

We use the double opt-in procedure for registration. This means that your registration will only be finalized when you confirm a link contained in a confirmation email sent to you for this purpose prior to your registration. In this way, we ensure that only you, the owner of the email address, can register.

After successful registration, we will create a personal user account for you through which your progress in the game and other information connected with the use of the App can be saved on our servers.

With your login data you can also identify yourself on other devices and use the treasure hunt app installed there with your user account.

You cannot log out on a device in the app itself. The login remains in the app until you log in with other login data or on another device with your login data.

After logging off, access to the information, saved in your user account, will only be possible by entering your password.

If you forget your password, you can use your email address to reset your password. To do this, click on the “?” on the login screen and follow the instructions.

As long as you do not log off, your login information will be saved in a “token” on your device, through which you can be identified so that you do not have to register again every time you use the App.

You can make changes to your personal user account by adding additional information within the account. Thus, you can, for example, enter your name, address or sex, select a team name or add a team photo in your user account. We use this data if we contact you and when you use the app as described below. The data will be saved on our server until you change the saved data or delete your user account.

5. Collection and use of data when using the treasure hunt App

When you use the KTG App, we collect and use the following data for the purposes described:

a. Location data

To be able to use the app and to play an event / a game fully, it is necessary to determine and use your current location. Your location will only be collected, in accordance with the consent you submitted at the time of registration, if you have activated the location function of your device and have allowed the KTG App to process your location data. We collect and use your location data as follows:

While you are playing, the KTG App will transmit your current location via GPS and/or device ID location in short intervals of approximately 15 to 25 seconds, usually to the nearest metre.

The most recently transmitted location will be saved and used by your device to show you your current location on the map and to check if you are close to a event / game task.

Your current location will also be transmitted to our servers and saved there in accordance with the consent you submitted. This is to allow KTG, partners of KTG or other organizers of the event / game / application to determine where individual participants of the game / event are, so that they can offer them support if necessary.

If you reach the location of a task, we save your location as well as the date and time when you reached the location of the task and when you completed the task. The purpose of this is to determine how much time you needed for the event / game / application and each of the tasks, including in comparison with other players.

We save the location data transmitted to our servers until the game / event is over. This data is then deleted from our servers. The most recent transmitted position on your device will remain saved in the App until a new position can be transmitted or the App is uninstalled.

Sometimes it can be, when allowed by the event / game organizers, that you share your current location with fellow players of the game / event in your vicinity and shown together with your user name, team name and team photo on the map. Similarly, you can also see the locations of your fellow players on the map during a game / event and, for example, work together to solve a task.

This collection and use is only possible if you have given your data protection consent separately. You can read the consent statement below.

You can stop the collection of your location data temporarily or permanently at any time by deactivating the location function in your device’s settings or withdrawing your permission for the processing of your location from the Game App. Please note that you can only participate in events / games to a very limited extent via the Game App because most of the tasks can only be solved if you are in the location and if this can be tracked.

b. Submission of solutions

The solutions submitted by you in response to a task will either be compared with the model solution on your device or transmitted to our servers and saved and checked there. We will use the result of this check to calculate your points, which will be displayed in the high score list.

Your solution entries can also be viewed and checked in the Content Management System on our server by the respective organizer of the game / event or by KTG for support purposes.

Please note: The game / event creator / organizer can request further personal data from you within the game / event by answering tasks. We would like to point out that this information is always provided voluntarily. Like all other game data, the data will also be processed by KTG and the implementing partner / organizer.

Partners / organizers / event and game creators are generally obliged to strictly avoid personal data in events / games / tasks. In particular, we ask that you do not provide any information about racial or ethnic origin, political opinions, religious or philosophical beliefs or trade union membership, genetic data, biometric data, health data or data about sex life or sexual orientation, or data about criminal convictions and crimes.

If you are requested to provide such data by answering a task or if such data is processed in the task itself, please contact info@karlsruhe-tourismus.de directly. If you decide to respond nevertheless, you also agree that KTG and the organizer/event creator will process the corresponding responses.

c. Connection speed

We collect and use the speed of your device’s internet connection to optimize your use of the App, particularly in connection with the download of event data. We also use the information about your connection speed for statistical analyses of the network coverage in the area of an event / game in order to transfer tasks in future games / events to other areas should any problems occur.

d. Battery status

We collect and save your current battery status so that we can inform you if your remaining battery life will not be sufficient for the entire event / game / application.

If devices of the KTG or off the respective organizer are used, we will also use the battery status to inform players to exchange the device in good time.

6. Other uses of data

If you participate in an event via the App that is organized by KTG or by a partner of KTG, the employees of KTG or the employees of the partner can, for the purpose of carrying out the event / game / application and providing support, access your data as described above and your data saved on our servers, and contact you during your participation in an event / game / application by means of in-app push notifications. This is only possible if you have submitted your consent.

If you are one of the top ten best players of an event / game / application, your rank, team name and statistics related to the tasks you have completed in the high score list will be shown to the other players of the event.

7. App permissions

To be able to use the KTG App with all the functions, the App requires the following permissions on your mobile device.

You can restrict the individual permissions in your device settings in accordance with your preferences, but the Game App might then only function to a limited extent.

The following permissions will be required by the App for the purposes described:

Permission Purpose
Camera The camera function of your mobile device will be accessed to scan QR codes, AR-Elements and to take photos and videos if these are required to make team photos or to solve a task.

Location We will transmit your current position during a game / event via the GPS function and/or device ID location of your mobile device to show you, the game organizers and possibly also your fellow players your current location on the map, as well as to check if you are close to a task.

Memory Permission to access the memory is required to save your pictures and videos on your device.

This permission can also cause information concerning a game / event to be saved on your device so that the App can also be played without an active internet connection (restricted).


8. Deletion of data

You can delete the information saved on your device at any time by uninstalling the App via your operating system. If you have activated a cloud solution to synchronize your device (e.g. Samsung Cloud or Apple iCloud), it may be necessary for you to delete the safeguard saved in the cloud to delete the data saved in the cloud.

Images taken with the treasure hunt App are saved on your device and are not automatically deleted from your device when the app is uninstalled. The KTG App is not authorized to do this under requested permissions. This is a security setting for the iOS and Android operating systems.

The information saved on our servers under your user account can be deleted at any time upon your request. Please write an email with your request to info@karlsruhe-tourismus.de.

9. Involvement of service providers

Your information will be shared with technical service providers (e.g. the App developer, server hosting, etc.) who support us in order to prepare the App and for the aforementioned purposes. They are chosen carefully by us and their engagement is formalized in writing. These service providers are obligated to follow our instructions and are controlled by us regularly.

10. Visual Studio - App Center

One of our service providers is the platform appcenter.ms. In the case of an app crash, we receive crash reports via this platform. Crash reports help us to track and correct mistakes in the app. The following data will be transmitted to appcenter.ms during the app crash and communicated to us:

App name, version code, version, operating system, manufacturer of the device, model, type of crash, crash date, account ID, team ID as well as the team name, the set language, event ID and server time.

11. Your data protection permission

To collect and use your location data, solution data, as well as for the KTG and the possibility to contact you, we require your consent, which we will ask you to submit during your registration.

You must be at least 16 years old to consent to the processing of your data. If you are not yet 16 years old, you confirm with this consent that you have asked your parents or another legal guardian for permission.

This consent is as follows/reproduced here:

Data protection consent

"I consent to the continuous transmission of my current location to the KTG in connection with my participation in an event / game via the KTG App for technical operational purposes, as well as transmission to other participants of the event / game for the purpose of joint play. My user name, my team name and team photo can also be shown on the map.

I also agree that my team name/user name can be used on the devices of other players of the event / game in which the high score and statistics view may be displayed among the top 10.

I also accept that the local company organizing the event / game can access the information transmitted from me to the servers for the purpose of carrying out the event / game as well as for support purposes, and it can contact me on this basis during my participation in the form of in-app push notifications.

I agree that other players can see my points and the number of right and wrongly solved tasks in an event, compared to myself, in the high score and in the statistics of the app.

With reference to point 5.b of this declaration, I agree that the provision of further personal data in events and tasks, e.g. when entering a solution, when entering a chat message or when sending a photo, is always voluntary and these entered personal data are also processed by KTG and the organizer / event creator.

I agree that in case of an app crash data can be forwarded to appcenter.ms and evaluated by KTG.

I can withdraw this consent at any time with effect for the future."

12. Withdrawal of your consent

If you want to withdraw your consent, please send your withdrawal request, if possible, to the email address info@karlsruhe-tourismus.de.

Following withdrawal of consent, you can unfortunately no longer take part in events / rallies / games via the KTG App, because the App relies on the collection and use of your location data, and we will delete the user account concerned.

However, you can register in the App again at any time and resubmit your consent.

Once we receive your withdrawal request, we will delete any location data concerning you on our server. If you wish, please delete information on your device as per paragraph 8 above because we are unable to do this.

13. Data security

We use technical and organizational security measures to protect saved or collected personal information, particularly from accidental or deliberate manipulation, loss, destruction or attack from unauthorized persons. Our security measures are continuously improved in accordance with developments in technology. In particular, data transmission between the App and our servers is always encrypted in order to prevent access by unauthorized third parties. In particular, data is transmission between the app and our server is only encrypted to prevent access by unauthorized third parties.

The data saved on your device will be protected from unauthorized access by the technical security measures of your device’s system, particularly by means of encryption. Please note that we do not have any possibility of control or access that can enable us to check that these measures used by your device, operating system and any security software you have installed provide sufficient protection in any individual case.


January 2021