Privacy Policy for our Apps


1. Name and contact details of the controller and the company data protection officer

This privacy policy applies to data processing performed by the following controller:

HABA Digital GmbH

Linienstr. 130

10115 Berlin



(hereinafter “We“, “Us“)

You can reach our data protection officer at the address above. Please add the line “Data protection officer” to the address.

2. Collection and retention of personal data, type and purpose of its use and the respective underlying legal basis

From the app store, you can download our mobile app “Digitalwerkstatt Art Studio” (the “App“) and use it on your mobile device after installing. None of the personal data collected from you or the user of the App will be used under any circumstances for the purposes of making conclusions about your person or the user by way profiling.

  • Information collected by downloading the App:

Upon downloading the App, certain necessary information is transmitted to your selected app store (Google Play or Apple App Store) and the following data may be processed, in particular:

  • your username,
  • your email address,
  • customer number of your account,
  • the date and time of the download, as well as
  • payment information and individual device number.

The collection and processing of this data occurs exclusively through the respective app store and is outside of our influence.

  • Use of the App

In the App, children can create their own artworks and lose themselves in the world of shapes, colors and lines. For this purpose, the following permissions on the mobile device are necessary:

  • Camera access and access to the internal memory of the mobile device: This is necessary in order to store created artworks.

The legal basis for the processing of this personal data is the performance of a contract according to Art. 6 para. 1 sentence 1 lit. b of the GDPR.

  • Support

You can reach Us via email for your support questions regarding our App. In order to process your request, We will collect and process the following personal data upon receiving an email from you:

  • your email address,
  • your name, and
  • the mobile device used.

Further information can be offered voluntarily by you. We will only use this data for corresponding with you. The legal basis for this data processing is the performance of a contract according to Art. 6 para. 1 sentence 1 lit. b of the GDPR.

3. Forwarding of data

There is no transfer of your personal data to third parties for any purposes other than the ones listed below.

We will only forward your personal data to third parties if:

  • you have given your explicit consent according to Art. 6 para. 1 sentence 1 lit. a of the GDPR,
  • the transfer is required for the assertion, exercising, or defense of legal claims according to Art. 6 para. 1 sentence 1 lit. f of the GDPR and there is no reason to assume that you have an overriding protectable interest in the non-forwarding of your data,
  • there is a legal obligation for the forwarding according to Art. 6 para. 1 sentence 1 lit. c of the GDPR, and
  • this is legally permissible and necessary under Art. 6 para. 1 sentence 1 lit. b of the GDPR for the fulfillment of the contractual relations with you.

4. Provision of information by your child

We do not use our App to knowingly collect or market data of persons under 16 years old. However, if you notice that your child has provided Us with information without your consent, please get in touch with Us via email at (). We will delete this information about your child from our database within a reasonable period.


In addition to the data privacy regulations applicable in Europe and Germany, we also comply with the regulations of the US American Children’s Online Privacy Protection Act (COPPA). This includes the fact that We do not knowingly collect personal data of children under 13 years old and that if a user identifies themselves through a support query or feedback as a child under 13 years old, we do not collect, store or use personal information of such a user and erase it in a secure manner.

6. Rights of affected persons

You have the right:

  • under Art. 15 of the GDPR, to request information about your personal data that We process;
  • under Art. 16 of the GDPR, to request the rectification of inaccurate or incomplete personal data about you stored by Us;
  • under Art. 17 of the GDPR, to request erasure of the personal data stored by Us;
  • under Art. 18 of the GDPR, to request restriction of the processing of your personal data;
  • under Art. 20 of the GDPR, to receive your personal data provided to Us in a structured, common and machine-readable format and to request transfer to another controller;
  • under Art. 77 of the GDPR, to file a complaint with a supervisory authority. In general, you can appeal to the supervisory authority of your primary place of residence, your workplace or our company’s headquarter.

7. Right to object

As far as your personal data is processed based on legitimate interests according to Art. 6 para. 1 sentence 1 lit. f of the GDPR, you have the right under Art. 21 of the GDPR to object to the processing of your personal data on grounds relating to your particular situation or because of data procession for the purpose of direct marketing. In the latter case, you have a general right to object that we will implement without requiring any particular situation. Otherwise, We will also stop processing your personal data unless We can prove that there are compelling legitimate reasons for the processing that override your interests, rights and freedoms, or if the processing serves the assertion, exercise or defense of legal claims.

If you would like to exercise your right to revoke or object, an email to is sufficient.

8. Period of data storing

We will delete your personal data as soon as it is no longer required for the purposes for which we have collected or used it under this privacy policy. Specific information in this privacy policy or legal requirements for the storage and deletion of personal data, in particular those that we must retain for tax reasons, remain unaffected.

9. Data security

We make use of appropriate technical and organizational security measures in order to protect your data against accidental or malicious manipulations, partial or total loss, destruction and unauthorized access by third parties. Our security measures are continuously being improved in accordance with technological developments.

10. Updates and changes to this privacy policy

This privacy policy is currently valid as of June 2019.

Due to the continuing development of our App or due to changes in legal or official requirements, it may become necessary to change this privacy policy from time to time. You may access and print out the current privacy policy at any time at: