Comico Games UG — Privacy Policy

Last updated: 2026-08-27

1. Who we are

This privacy policy explains how Comico Games UG (of Darmstädter Landstraße 116 Frankfurt am Main Hessen 60598 Germany) (“we”, “us”, “our”) collects, uses, and protects your personal data when you visit our game page, sign up, join our waitlist or wishlist, or otherwise interact with us in connection with Screenplay.

We are the controller of the personal data we collect about you through our game page.

If you have any questions about this policy or your personal data, you can contact us at https://www.comicogames.de/contactus/.

2. The personal data we collect

Information you give us. When you sign up, join our waitlist or wishlist, or otherwise contact us, we collect the details you provide, such as your name and email address, together with your marketing preferences and the consents you give us.

Information we collect automatically. When you visit our game page, we automatically collect certain information about your device and how you use the page such as your IP address, approximate location, browser and device type, the pages you view, the website or search terms that referred you, and how you interact with the page. We collect this using cookies, log files, and similar technologies such as pixels and web beacons (see “Cookies and similar technologies” below).

Providing your details is voluntary. If you do not provide them, you may not be able to register your interest or receive marketing communications from us.

3. The Immutable platform

Our game page runs on technology provided by Immutable. Immutable processes your data on our instructions for the activities described and also processes data across the wider platform for its own purposes. Those activities are explained in Immutable's own privacy policy which you should read alongside this policy.

What Immutable does for us (as our processor). On our instructions, Immutable collects and provides to us certain data about how players interact with our game and our marketing, so that we can understand our audience and run and measure our campaigns:

• Player and game data. Immutable collects data about how players engage with our game page and our content, such as sign-ups, activity and engagement within our game, and makes it available to us so we can understand and segment our own audience.
• Advertising measurement. If we run paid advertising, Immutable measures which advertising led to which activity on our behalf. As part of this it sends limited conversion information from its servers to advertising platforms, an advertising identifier, the type of event, and any purchase value, so we can measure how our campaigns perform.
• Marketing sign-ups and campaigns. When you choose to follow our game or sign up for updates, Immutable records your marketing consent on our behalf, and delivers our marketing and lifecycle campaigns to players who have consented on our instructions.

What we see from the Immutable platform is limited to pseudonymised records and insights about our own audience. Unless you give your express consent, we are not able to precisely identify you from this data.

4. How and why we use your personal data

We use your personal data for the purposes set out below. Where the law requires a legal basis for our processing, the relevant basis is shown alongside each purpose:

• To send you marketing communications about Screenplay, including updates, announcements, beta access, and launch information — legal basis: your consent.
• To register and manage your sign-up, waitlist, or wishlist entry — legal basis: performance of a contract / taking steps at your request, and our legitimate interests in operating our game page.
• To operate, secure, and improve our game page, including to detect and prevent fraud or misuse, and to understand how it is used — legal basis: our legitimate interests in running, protecting, and improving our services.
• To create customer/player profiles to enable us insights into player behavior to allow us to better understand the use of and improve and target our offers and products — legal basis: our legitimate interests in running, protecting, and improving our services / your consent.
• To measure and optimise our marketing and advertising activities — legal basis: our legitimate interests (and your consent, where we rely on cookies or similar technologies).
• To comply with our legal obligations and to establish, exercise, or defend legal claims — legal basis: compliance with a legal obligation / our legitimate interests.

Where we rely on your consent, you can withdraw it at any time (see “Your rights” below). Withdrawing your consent does not affect the lawfulness of any processing we carried out before you withdrew it.

We do not use your personal data to make decisions about you based solely on automated processing that produce legal or similarly significant effects.

5. Who we share your personal data with

Where necessary for the above purposes, we may share your personal data with:

• Service providers and technology partners who help us operate our game page, store data, and assist us in our marketing activities, who, in each case, process personal data on our behalf and on our instructions.
• Third-party advertising platforms, such as TikTok and Reddit, where we run advertising. These platforms act as independent controllers of the limited data they receive to measure and improve advertising, and their own privacy policies explain how they use it.
• Our professional advisers, and regulators, courts, or law enforcement where we are required or permitted by law to do so.
• A buyer or successor (and their advisers) if we sell, transfer, or reorganise all or part of our business.

6. Targeted advertising

How advertising is measured for our game, and the role Immutable plays, is described in “The Immutable platform” above. Where advertising relies on cookies or similar technologies, your consent is required.

7. Do Not Track and Global Privacy Control

Some browsers send “Do Not Track” or “Global Privacy Control” signals. Our game page does not currently change its behaviour in response to these signals.

8. International transfers

Your personal data may be transferred to, stored in, or accessed from countries outside the European Economic Area / United Kingdom. Where we do this, we put in place appropriate safeguards to protect your personal data such as the European Commission’s Standard Contractual Clauses or the UK International Data Transfer Agreement (or Addendum).

9. Your rights

Depending on where you are located and the laws that apply, you may have the right to:

• ask for access to the personal data we hold about you;
• ask us to correct personal data that is inaccurate or incomplete;
• ask us to delete your personal data;
• object to, or ask us to restrict, our processing of your personal data;
• ask us to provide certain personal data to you, or another organisation, in a portable format;
• withdraw your consent at any time, including by using the unsubscribe link in any marketing email or by contacting us; and
• lodge a complaint with your data protection supervisory authority (in the EU, your local supervisory authority; in the UK, the Information Commissioner’s Office). We would welcome the chance to address your concerns first.

To exercise any of these rights, please contact us at https://www.comicogames.de/contactus/.

10. How long we keep your personal data

We keep your personal data only for as long as we need it for the purposes set out in this policy, including to meet any legal, accounting, or reporting requirements. Where we process your data on the basis of your consent for marketing, we keep it until you withdraw that consent or it is no longer needed for that purpose, whichever comes first.

11. Cookies and similar technologies

Our game page may use cookies and similar technologies (such as pixels and web beacons) to make the page work, to remember your preferences, to understand how the page is used, and where you use them to support advertising. Where the law requires it, we will ask for your consent before setting any non-essential cookies.

12. Changes to this policy

We may update this policy from time to time. When we do, we will post the updated version on this page and change the “last updated” date at the top.

13. How to contact us

If you have any questions about this policy, or about how we handle your personal data, please contact us at https://www.comicogames.de/contactus/.