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Privacy Policy

Last updated: 6 November 2026

1. Data protection at a glance

The protection of your personal data is important to us. This privacy policy informs you which personal data we process when you visit this website, for what purpose, and on what legal basis. Personal data is any data that can be used to identify you personally.

This website follows a data-minimal approach: we use no cookies (the only thing stored on your device is a note that you dismissed our information notice, see section 7), no tracking or analytics services (such as Google Analytics), no social media plugins and no advertising. The fonts are delivered from our own server, and so are all images; nothing is loaded from third parties (see section 8). Personal data is essentially only processed when the website is delivered to you technically (server logs) and when you sign up for the launch notification or contact us.

2. Controller

The controller within the meaning of the General Data Protection Regulation (GDPR) is:

Seifert AviationSoftware
Owner: Kilian Seifert
Am Ziegelland 47
85604 Zorneding
Bavaria, Germany
Phone: 0151 11257196
Email: software@seifert-aviation.de

We are not required to appoint a data protection officer. For any questions about data protection, please contact the controller named above directly.

3. Hosting and server log files

This website is hosted by an external service provider, Railway Corp. (USA), on servers in the EU (region “EU West”, Amsterdam, Netherlands). The personal data collected on this website is stored on the host's servers. Insofar as the host processes personal data on our behalf, we have concluded a data processing agreement (DPA) with them in accordance with Art. 28 GDPR. Because the host is a company based in the USA, access from the USA cannot be completely ruled out; the data processing agreement with the host covers this.

The host and its web server automatically collect and store information in so-called server log files, which your browser transmits automatically. These are:

  • the IP address of the requesting device
  • date and time of access
  • name and URL of the file accessed
  • browser type and version used
  • operating system used
  • the website from which access was made (referrer URL)
  • amount of data transferred and notification of successful retrieval

This data is not combined with other data sources. Processing is based on our legitimate interest in the technically error-free presentation and security of the website (Art. 6(1)(f) GDPR). The log files are stored for a limited period of time for security reasons and then deleted; the exact retention period depends on the host's specifications.

The domain is registered with IONOS SE (Montabaur, Germany). The DNS records of the domain are served by Cloudflare, Inc. (USA) in “DNS only” mode: Cloudflare answers DNS queries for the domain, but no website traffic is routed through Cloudflare.

4. Launch notification (email sign-up)

If you sign up for the launch notification, we process your email address and technical proof data: the time of sign-up and of confirmation and the version of the consent text shown. We do not store IP addresses with your sign-up.

Purpose: we write to you once when the game is released. Legal basis: your consent (Art. 6(1)(a) GDPR, § 7(2) no. 3 UWG), which you give by ticking the box in the form.

Double opt-in: after you sign up we send a confirmation email. Only after you click the link in it and confirm on the page that opens is your address registered for the notification. Right after that we send you one short email confirming your registration. Unconfirmed entries are deleted automatically after 7 days.

Abuse protection: to prevent misuse of the form (for example mass sign-ups of third-party addresses) we briefly keep a technical request counter in the server's memory. It is not written to our database and is discarded after a short time. This is based on our legitimate interest in the secure operation of the form (Art. 6(1)(f) GDPR).

Retention: until you unsubscribe, and at the latest 6 months after the game's release. After that your address is deleted.

Withdrawal: you can withdraw your consent at any time with effect for the future – via the unsubscribe link that every email from us contains (including the confirmation email) or by an informal message to us. Unsubscribing deletes your address immediately. The lawfulness of processing carried out before the withdrawal remains unaffected.

5. Email delivery

To send the confirmation email and the launch notification we use Brevo (Sendinblue SAS, France) as a processor, with a data processing agreement under Art. 28 GDPR. We keep the recipient list ourselves; the provider only receives the data needed to deliver a message (recipient address, content of the email). Open and click tracking is switched off, so no tracking pixels or redirected links are used in our emails.

6. Contacting us

You can contact us by email or phone. Emails to addresses of this domain (for example info@tinytrains.net) are forwarded to our mailbox by the email routing service of Cloudflare, Inc. (USA), which therefore technically passes on the content of such emails without storing it. If you prefer, you can write directly to the address in the legal notice. We store the personal data you send us in order to handle your request (Art. 6(1)(b) or (f) GDPR) and delete it once it is no longer needed, unless statutory retention periods apply.

7. Cookies and local storage technologies

This website does not use any cookies, no tracking and no analytics. The only thing stored on your device is one small entry in your browser's local storage (titra-notice) that remembers that you have dismissed the information notice about cookies, so that it does not appear on every page. This entry stays on your device, contains no personal data and is not transmitted to us or to anyone else. It is strictly necessary to provide the function you have used (dismissing the notice), so no consent is required under § 25(2) no. 2 TDDDG. You can delete it at any time in your browser settings; the notice will then be shown again. Server log files (section 3) are not a storage on your device within the meaning of § 25 TDDDG.

8. Fonts and images (hosted locally)

For a consistent appearance this website uses the fonts “Fraunces” and “Nunito”. The font files are loaded from our own server and not from external servers (such as Google Fonts). The same applies to all images. No connection to third-party servers and no transmission of your IP address takes place in this context.

9. SSL/TLS encryption

For security reasons and to protect the transmission of confidential content, such as your email address when signing up, this site uses SSL/TLS encryption. You can recognise an encrypted connection by the address line of your browser changing from “http://” to “https://” and by the lock symbol in your browser bar.

10. External links

This website currently contains no links to external websites. Should links to the app stores be added, these contents are not embedded in our page but only called up when you actively click the respective link. By clicking, you leave our website; the respective provider is responsible for the subsequent data processing. Please note their privacy policies.

11. Your rights as a data subject

  • Access (Art. 15 GDPR): you have the right to obtain confirmation as to whether personal data concerning you is being processed, and access to that data and further information (purposes, categories, recipients, retention period).
  • Rectification (Art. 16 GDPR): you have the right to have inaccurate data corrected and incomplete data completed without delay.
  • Erasure (Art. 17 GDPR): you have the right to have your personal data deleted, unless statutory retention obligations or other reasons prevent this.
  • Restriction of processing (Art. 18 GDPR): you have the right to request restriction of processing under certain conditions.
  • Data portability (Art. 20 GDPR): you have the right to receive the data you have provided to us in a structured, commonly used and machine-readable format.
  • Withdrawal of consent (Art. 7(3) GDPR): you can withdraw a consent given at any time with effect for the future.
  • Complaint (Art. 77 GDPR): you have the right to lodge a complaint with a data protection supervisory authority.

Right to object (Art. 21 GDPR)

Where the processing of your personal data is based on legitimate interests under Art. 6(1)(f) GDPR, you have the right to object at any time, on grounds relating to your particular situation. We will then no longer process the data concerned unless we can demonstrate compelling legitimate grounds that override your interests, rights and freedoms, or the processing serves the establishment, exercise or defence of legal claims.

Competent supervisory authority

Bayerisches Landesamt für Datenschutzaufsicht (BayLDA)
Promenade 18
91522 Ansbach, Germany
Website: https://www.lda.bayern.de

12. Objection to advertising emails

We hereby object to the use of contact details published as part of the legal notice obligation for sending advertising and information material that has not been expressly requested. The operators expressly reserve the right to take legal action in the event of unsolicited advertising, for example spam emails. (This does not affect the launch notification you have expressly consented to.)

13. Changes to this privacy policy

We reserve the right to adapt this privacy policy so that it always meets current legal requirements or to implement changes to our services, for example when introducing new features. The new privacy policy then applies to your next visit.

14. Questions about data protection

If you have questions about the collection, processing or use of your personal data or about exercising your rights, please contact the controller named in section 2:
Kilian Seifert, Seifert AviationSoftware, Am Ziegelland 47, 85604 Zorneding, Germany
Email: software@seifert-aviation.de

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