Please note that this is a machine-translated version as an aid to understanding for non-German speakers, but only the German version is legally valid.
Privacy Policy for the Use of the Computer Game “Qookies”
General Privacy Policy for the Use of the Computer Game “Qookies” (hereinafter referred to as the “Computer Game”) of the Chair of Physics Education at Ludwig-Maximilians-Universität München (hereinafter referred to as “LMU”). This privacy policy explains how personal data is processed by LMU in connection with the use of the Computer Game. It also informs users of the Computer Game about their rights. For reasons of readability, gender-specific language forms are not used. All gender references apply equally to all genders.
A. General Data Protection Information
LMU is a public university of the Free State of Bavaria (Article 4 (1) Sentence 1 No. 1 of the Bavarian Higher Education Innovation Act, BayHIG). It is a public law corporation with the right to self-administration within the framework of the law and at the same time a state institution (Article 4 (1) BayHIG). LMU performs its own matters as a corporation and state matters as a state institution (Article 4 BayHIG).
I. Contact Information in Connection with LMU’s Website
I.1. Information on the Data Controller at LMU
The Chair of Physics Education at LMU is the data controller responsible for system maintenance and the content created by LMU in connection with the computer game:
Chair of Physics Education
Ludwig-Maximilians-Universität München
Geschwister-Scholl-Platz 1
80539 Munich
Germany
The respective task creators are responsible for the tasks and content areas created and provided by users within the computer game.
I.2 Information on the Data Protection Officer of LMU
The contact details of the Data Protection Officer of LMU can be found on the LMU website at https://www.lmu.de/datenschutz [German]. The Data Protection Officer is available to answer questions regarding data protection at LMU. Please use the contact form provided on the website of the LMU Data Protection Officer at https://www.lmu.de/datenschutz [German] for this purpose.
II. Information on Data Processing
II.1 Scope of this Privacy Policy
This privacy policy applies to the processing of personal data in connection with the computer game “Qookies.”
- According to Article 4(1) of the GDPR, “personal data” means any information relating to an identified or identifiable natural person; 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.
- According to Article 4(2) of the GDPR, “processing” means 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, organization, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction.
II.2 Purposes and Legal Bases for the Processing of Personal Data
The purpose of the data processing is to provide and improve the computer game “Qookies”. The game and the associated data processing, both within and after gameplay, are conducted as part of the scientific research project “GALaQSci”. The aim is to better understand user behavior in game-based learning environments, particularly in interaction with AI-based support systems. The data is used exclusively for scientific analysis and is not used commercially or shared with third parties. Personal data is only collected and processed to the extent necessary to link data collected within the game (see below) with questionnaire data collected outside of the game. In processing your personal data, we particularly observe the data protection principles of lawfulness, fairness, transparency, purpose limitation, data minimization, accuracy, storage limitation, integrity, and confidentiality. Wherever and as soon as the purpose of the processing permits, personal data will be anonymized or pseudonymized. We ensure through an appropriate IT security infrastructure that only those individuals within our organization who need access to this information to perform their duties are granted such access. Personal data is treated confidentially and is not disclosed to unauthorized third parties, in particular not to the public. The legal basis for the collection and processing of personal data is your consent in accordance with Article 6(1)(a) of the GDPR. The data processing is carried out in accordance with the applicable data protection regulations, in particular based on the General Data Protection Regulation (GDPR) and the Bavarian Data Protection Act. The collected data is processed exclusively for the purpose described in Section II.2. Data processing is also carried out to the extent necessary for the ongoing improvement of system operations, i.e., for quality assurance by the operators of the computer game. In the following section, we describe which personal data is processed.
II.3 What data is collected?
In the context of using the computer game, the following data is collected:
- Text input by users within the computer game, e.g., in chat with a language model that is hosted locally at LMU.
- Time spent per game level
- Timestamps of game events (e.g., level changes, interactions with the AI character)
- Screenshots of the game at the time of game events
- In particular, no collection of names, IP addresses, or device identifiers
When using the app, a randomly generated, device-related user ID is stored to enable pseudonymized analysis of the aforementioned data across different sessions. This ID does not allow any direct inference to the identity of the user. The user ID can be viewed in the settings of the computer game and may be used to exercise data subject rights (e.g., access or deletion).
II.4 Who has access to what?
- Project partners of the GALaQSci project from LMU, TUM, MPQ, Quantum Gaming, and Studio Merkas
- Anonymized and aggregated data will be published
II.5 Data security
To ensure the adequate and comprehensive protection of your data during processing and especially during transmission, we use appropriate encryption procedures (e.g., SSL/TLS) and secure technical systems as necessary and in accordance with the current state of the art. The technical operation of the data processing systems is supported by the Leibniz Supercomputing Centre (LRZ) of the Bavarian Academy of Sciences and Humanities (Boltzmannstraße 1, D-85748 Garching near Munich, Phone: +49 (89) 35831 8000, Fax: +49 (89) 35831 9700, Email: lrzpost@lrz.de, https://www.lrz.de), with which a data processing agreement has been concluded. All our employees are subject to the statutory data confidentiality obligations in accordance with Art. 11 BayDSG or are otherwise bound to confidentiality.
II.6 Data Transfers
Data transfers are carried out either based on legal requirements or with your consent. If necessary, your data may be transferred to the competent supervisory and auditing authorities in order to fulfill their respective oversight responsibilities. To counter threats to IT security, data transmitted electronically may be forwarded to the State Office for Information Security and processed there in accordance with Articles 41 et seq. of the BayDiG (Bavarian Data Protection Act).
In all other cases, we transfer personal data to third parties only if this is necessary for the performance of a contract (Article 6(1)(b) GDPR), for example to event organizers or contracted service providers. The data passed on may only be used by the respective data processor or third party for the specified purposes and in accordance with applicable legal provisions.
II.7 Data Deletion and Storage Duration
Your data will only be stored for as long as necessary to fulfill the intended purpose in compliance with statutory retention periods or if you have given your consent. Personal data of users of the computer game will be deleted or anonymized as soon as the respective purpose of storage ceases to apply and there is no obligation to archive. Where provided for in the relevant regulations, storage may also continue beyond this.
A review and execution of deletion takes place regularly and at least once a year. Operational data at LRZ: Access data and error messages (weblogs) generated during the operation of the web server are anonymized after 7 days. An incremental deletion of the anonymized logs takes place regularly every three months.
II.8 Protection of Minors
Persons under the age of 16 should not transmit personal data to LMU without the consent of their parents or legal guardians. Processing can only take place after obtaining the appropriate consent or within the scope of fulfilling a legal obligation.
II.9 Your Rights
You have various rights towards the responsible party regarding the data stored about you. Your rights include:
- Right of Access (Art. 15 GDPR): You have the right to obtain information about the personal data being processed about you.
- Right to Rectification (Art. 16 GDPR): If incorrect personal data is stored, you may request the data controller to correct the data. The controller will comply with the request provided the correction is justified and permissible.
- Right to Erasure (Art. 17 GDPR): You have the right to have personal data deleted if it is demonstrably incorrect or if the controller cannot justify a processing purpose. There is no right to deletion if the controller is obliged to retain the data due to legal reasons or official duties (e.g., proof of training, quality assurance documentation, copyright usage rights, examination law). A deletion request may be considered a withdrawal of consent, which may result in you no longer having access to the computer game or being unable to create a task.
- Right to Restriction of Processing (Art. 18 GDPR): The controllers will ensure that personal data is only accessible to persons who need to process it in the event of a legitimate restriction of processing. They may use pseudonymization and anonymization methods for this purpose.
- Right to Object (Art. 21 GDPR): You may object to the further use of your data under legal conditions. This objection only takes effect for the future. The right to object does not automatically oblige the controller to delete the data. If the controller has legal storage obligations, these take precedence. The objection may result in you no longer having access to the computer game.
- Right to Data Portability (Art. 20 GDPR): Under legal conditions, you have the right to receive data you have provided yourself in an electronic format that can be used elsewhere. This right is limited to data that is not subject to business secrets and thus may not be transferred to other parties or that affects the rights of others, such as their personal rights or copyright.
- Right to Withdraw Consent (Art. 7(3) GDPR): You have the right to withdraw your consent to the processing of your data for the future. Withdrawal does not affect the lawfulness of processing carried out before the withdrawal. Withdrawal may result in you no longer having access to the computer game or being unable to participate in a course. If the processing takes place under an employment contract, the right to withdraw may be limited.
- In case of violations of legal provisions concerning the protection of data stored about you, you may contact the competent supervisory authority. The data protection supervisory authority directly responsible for LMU is the Bavarian State Commissioner for Data Protection (https://www.datenschutz-bayern.de). Please contact the responsible party or the official data protection officer first so that your concern can be reviewed and addressed as quickly as possible.
Upon deletion, restriction, or withdrawal, further use of the computer game and participation in the available activities and functions is no longer guaranteed with immediate effect.