1Definitions

Personal data

Personal data is information about a natural person who can be identified, e.g. by association with an online identifier (email address, location data, etc.).

Valve

The Valve Corporation, based at 10400 NE 4th St., Bellevue, WA 98004, USA, hereinafter “Valve”, is a software company responsible for, among other things, “Steam”.

Steam

Steam is an online service operated by Valve. Valve is also the developer of the game “Counter-Strike: Source”, for which pureAim operates game servers.

Steam ID

The so-called Steam ID is a unique number that allows a player to be identified by Valve. Third parties can also access a Steam user’s profile picture, nickname, etc. via a public developer interface.

Cloudflare

Cloudflare, Inc., 101 Townsend Street, San Francisco, CA 94107, USA, hereinafter “Cloudflare”, is a provider of content delivery and security services, which we use, among other things, to defend against DDoS attacks.

2Controller

The controller within the meaning of the GDPR (European and other applicable data protection law) is:

3Cookies

When you visit one of our websites, we send one or more cookies to the device you use to access it. Cookies help us improve the quality of our services by storing user settings and generating statistics.

We use the open-source forum software phpBB for user management and as our forum system; it is embedded on almost all pureAim websites.

The following cookies are or may be set during a visit:

• pa-consent – stores your choice in the cookie banner (consent or refusal per category); storage period 180 days, valid for all subdomains of pureaim.org – technically necessary
• pa-theme – contains the preferred design (light / dark / automatic) set by the user.
• … _lang – contains the language (German / English) set by the user.
• … _tz – contains the time zone set by the user.
• … _u – contains the user_id (ID of the user)
• … _sid – ID of the current session
• … _k – key linking an auto-login, a session and a user
• style-cookie – contains information about which forum theme the user has activated
• __cf_bm – set by our service provider Cloudflare to distinguish humans from bots (defence against DDoS attacks, see item 5); the cookie usually has a storage period of 30 minutes and is technically necessary for providing the website
• _pk_id, _pk_ses, mtm_cookie_consent – Matomo cookies used to recognize visitors and measure sessions; they are set only after your consent to the “Statistics” category (see item 14)
• Third-party cookies from embedded services (e.g. YouTube), see further below

Standard phpBB privacy policy, see also: https://forum.pureaim.org/ucp.php?mode=privacy

Further cookies may be set when visiting sub-pages or submitting comments.

You can also disable the storage of cookies (including session cookies) directly in your browser settings; however, this may lead to restrictions in some website functions.

4Log data

When you access our websites, our servers and the service providers we use (including Cloudflare, see item 5) automatically store certain information. These server logs may contain the following information: the URL from which you came to our pages, your IP address, browser type, browser language, and date and time of your request.

When using this log data, pureAim does not draw any conclusions about the respective person; furthermore, it is stored separately from personal data. Log data is collected in order to deliver content correctly, to detect abuse and, in the event of a cyberattack, to provide law enforcement authorities with sufficient information. We partly use AI support to analyze log data (see item 11).

5Use of Cloudflare (DDoS protection and availability)

pureAim uses the services of Cloudflare, Inc., 101 Townsend Street, San Francisco, CA 94107, USA, in particular for protection against DDoS attacks and bot access, and to ensure the availability and performance of our web offerings.

Cloudflare operates as a so-called reverse proxy: all requests to our websites are first routed through the Cloudflare network before they reach our own servers. In doing so, Cloudflare automatically processes the following data: your IP address, the URL accessed, date and time of the request, the amount of data transferred, the browser type (user agent) and other technical connection characteristics. This processing is carried out for the purpose of defending against attacks and ensuring accessibility.

For this processing, Cloudflare acts as a processor within the meaning of Art. 28 GDPR. The required data processing agreement (Data Processing Addendum) is part of the terms of service concluded with Cloudflare and is automatically incorporated by reference for customers with a self-service subscription. Data transfers to the USA are safeguarded through Cloudflare’s certification under the EU-US Data Privacy Framework. Further information can be found in Cloudflare’s privacy policy: https://www.cloudflare.com/privacypolicy/

To distinguish legitimate users from automated programs (bots), Cloudflare may store the “__cf_bm” cookie on your device (see item 3). This is absolutely necessary for providing a secure, DDoS-protected web offering.

6Use of the Steam API / Steam login

pureAim uses Valve’s Steam API. This developer interface makes it possible to verify the validity of a transmitted Steam ID and to request further information such as the profile picture and nickname. pureAim requires this information to effectively enforce player sanctions and to display the player ranking. This information is also used for the sanction system at bans.pureaim.org.

pureAim also uses the so-called “Steam login”, likewise provided by Valve. This step is necessary when registering on the pureAim forum in order to verify the respective account. Only after clicking the correspondingly labelled “I agree to these terms” or “Steam login” button is the user redirected to Valve to log in with their Steam credentials. During this step, Valve may collect general log data (IP address, browser used, time, browser language) and may recognize from which website the user clicked the Steam login button.

7Use of chat, forum and comments

When using the in-game chat, our forum or the comment section, each published post stores the chosen nickname, timestamp, Steam ID and IP address. This storage is necessary for security reasons in order to be able to take appropriate action in the event of legal violations.

Forum registration also requires providing an email address, which is likewise linked to and stored with the created user account. Storing the email address is necessary to offer the “reset password” function and to prevent duplicate registrations.

The forum profile can also be extended with optional additional information (date of birth, instant messenger details), which is then stored and can be displayed accordingly. Storing the optional data is necessary to extend the forum profile with additional contact details; in addition, an optional date of birth allows the user to be shown a birthday greeting in the forum.

This personal data is not disclosed unless required by law or necessary to defend against legal violations.

Chat logs

All public server chat logs (in-game chat) can subsequently be viewed by every registered pureAim member in order to prove violations of our terms of use among players. When using the server chat, the respective published content is linked to the player’s Steam ID in our database. Chat logs can therefore be attributed to the respective player.

Steam verification in the forum

Registered pureAim forum users must first verify themselves with their Steam account in order to be able to post. Once verification is complete, the respective Steam ID is assigned to the forum account and stored accordingly in the database. Forum posts created can thus also be attributed to the respective Steam player profile. This measure is necessary to effectively enforce game sanctions and to provide VIP features.

News section

In the pureAim news section, registered pureAim members can comment on individual articles. These comments can likewise be attributed to the respective Steam profile once Steam verification has been carried out during registration.

8Retention period

Personal data of the data subject is only stored for the period necessary to achieve the purpose of storage or as required by law. Once this purpose no longer applies, personal data is routinely deleted in accordance with statutory requirements.

Comments, forum posts and the associated data remain on our website as long as the commented content has not been completely deleted or the comments have been removed for legal reasons.

9Rights of the data subject

Under the EU GDPR, the data subject is granted the following rights governing the processing of personal data. To exercise these rights, the data subject may contact the controller at any time (see item 2).

Right of confirmation

You may request confirmation as to whether personal data is being processed (see Art. 15 GDPR).

Right of access

You may request free information about the data stored about you at any time (see Art. 15 GDPR).

Right to rectification

The data subject has the right to prompt rectification; inaccurate personal data must be corrected. There is also a right to the completion of incomplete personal data (see Art. 16 GDPR).

Right to erasure (“right to be forgotten”)

You have the right to require the controller to erase personal data where certain grounds apply and processing is not necessary (see Art. 17 GDPR).

Right to restriction of processing

You have the right to require the controller to restrict processing where certain conditions are met (see Art. 18 GDPR).

Right to data portability

Every data subject has the right to receive the personal data stored about them in a common, machine-readable format (see Art. 20 GDPR).

Right to object

The data subject has the right, on grounds relating to their particular situation, to object at any time to the processing of personal data concerning them which is based on Art. 6(1)(e) or (f), including profiling based on these provisions (see Art. 21 GDPR).

Automated individual decision-making, including profiling

The data subject has the right not to be subject to a decision based solely on automated processing – including profiling – which produces legal effects concerning them or similarly significantly affects them (see Art. 22 GDPR).

Right to withdraw consent

Every person affected by the processing of personal data has the right to withdraw consent to the processing of personal data at any time (see Art. 7(3) GDPR).

Right to lodge a complaint

In the event of data protection violations, the data subject has the right to lodge a complaint with the competent supervisory authority. A list of the relevant data protection authorities can be found at https://www.bfdi.bund.de/DE/Infothek/Anschriften_Links/anschriften_links-node.html.

10Use of YouTube

pureAim has integrated so-called YouTube videos into its online offering. YouTube enables the free upload, viewing, rating and commenting of video content. YouTube is operated by YouTube, LLC, 901 Cherry Ave., San Bruno, CA 94066, USA, a subsidiary of Google LLC, 1600 Amphitheatre Pkwy, Mountain View, CA 94043, USA.

Each time a page containing an embedded YouTube video is accessed, the corresponding video elements are requested and downloaded by the web browser. This allows YouTube to recognize which sub-page the data subject is on; if the data subject is already logged into their YouTube account, this information may be collected and attributed to them. Logging out of the YouTube account beforehand prevents this attribution.

YouTube videos may be embedded on our main site, in our news section, and by our forum users in our discussion forum. When embedding videos, we use the “extended data protection mode” (also known as “youtube-nocookie”), so that fewer additional cookies are set by YouTube.

The privacy policy published by Google provides information on the collection and use of personal data and is available at https://policies.google.com/privacy.

11Use of artificial intelligence (AI)

For the administration and moderation of our offering, we use AI support in selected areas, in particular for checking log files (see item 4), for evaluating bans and player sanctions (sanction system at bans.pureaim.org) and for drafting forum replies.

These AI services are handled via the requesty.ai platform (hereinafter “requesty.ai”), a gateway service for accessing various AI models. requesty.ai is a processor within the meaning of Art. 28 GDPR; a data processing agreement has been concluded with the provider. The personal data arising in the course of this processing is processed exclusively within the European Union.

The AI-assisted evaluation helps us to efficiently detect abuse, to ensure system and forum security and to handle user enquiries. There is no decision based solely on automated processing which produces legal effects concerning you or similarly significantly affects you: sanctions and other measures are always finally reviewed and decided by our administrator team (see Art. 22 GDPR).

12Withdrawal option (cookie consent, statistics and YouTube)

You may withdraw your previously given consent to the cookie consent banner at any time. This will deactivate embedded YouTube videos again on all pureaim.org websites and delete Matomo visitor cookies; statistics then continue in cookieless mode. You can find your current status, including the option to withdraw consent, in the cookie settings window, which is accessible via the corresponding link in the footer of every page.

13Links

Further information on outgoing links from our website.

Amazon Associates Program

pureAim (owner: Stefan Kröll) participates in the Amazon EU Associates Programme operated by Amazon Europe Core S.à r.l., 38 avenue John F. Kennedy, L-1855 Luxembourg, an affiliate advertising programme designed to provide a means for websites to earn advertising fees by placing ads and links to Amazon.de. Amazon can recognize when you click on a corresponding affiliate link on this website. Corresponding cookies are only set once the actual Amazon page is visited; we do not use Amazon tracking cookies.

Facebook

We link to Facebook in order to offer the share function. Facebook is operated by Meta Platforms Ireland Limited, 4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Ireland. For the share function we use ordinary hyperlinks, so no data is transmitted to Facebook merely by visiting our website. Only after clicking a link marked accordingly as leading to Facebook do you reach Facebook, where data may be collected over which we have no influence.

14Tracking and profiling

pureAim uses the web analytics software Matomo (www.matomo.org), a service provided by InnoCraft Ltd., 150 Willis St, 6011 Wellington, New Zealand (“Matomo”). The data collected using Matomo technology (your IP address is anonymized before storage) is processed on our own servers. Processing serves the statistical analysis of user behaviour for optimization purposes.

Whether and how Matomo recognizes visitors depends on your choice in the cookie banner:

• Default (no consent, “cookieless”): Matomo measures your visit without any cookies. No visitor cookies are stored on your device and no information is read from your device; visitors are not recognized across visits. Processing is based on our legitimate interest (Art. 6(1)(f) GDPR) in statistical reach analysis and optimization of our services.
• With your consent to “Statistics”: Matomo sets visitor cookies (_pk_id, _pk_ses, mtm_cookie_consent) to recognize visitors across page views and visits and to create and evaluate pseudonymized usage profiles. The legal basis is your consent (Section 25(1) TDDDG in conjunction with Art. 6(1)(a) GDPR).

The collected information is not used to personally identify the visitor of this website and is not combined with personal data about the holder of the pseudonym.

If you also object to cookieless measurement, you can opt out at any time. To do so, untick the box below; an opt-out cookie is then placed in your browser so that Matomo no longer collects any visitor data. The same field is available in the cookie settings window. Please note that completely deleting your cookies also deletes the opt-out cookie, so your objection may need to be set again.

15Right to information

You have the right at any time to request information about the data stored regarding your person. At the data subject’s request, the controller will also carry out corrections or deletions of personal data, provided there are no statutory retention obligations to the contrary. For information about stored data or to submit deletion requests, please contact us by email at: [email protected]

or send a request to: