Data Protection Policy

This Policy applies to the processing that we conduct on your Personal Data when you use one of our games (each the "Game" and together the "Games") and describes the manner in which the data are collected and processed by our company.

It is specified that certain provisions are identified as applying only to residents of certain countries by exception to the common rules of this Data Protection Policy.

If you are a US resident, the following provisions apply to you: This Data Protection Policy sets forth what personal and usage information Davy’deo collects through the Game, as well as how that information is used, maintained, and in some cases, shared with third parties. This Data Protection Policy also sets forth how to contact Davy’deo if you have any questions about the privacy of your information. By accessing or using any part of the Game you acknowledge that you are expressly accepting and consenting to the practices and policies outlined in this Data Protection Policy. All Disputes are governed by the terms set forth in Davy’deo’s General Terms of Use http://davydeogamesstudio.com/en/TermAndConditions.html.

This Data Protection Policy applies only to information that you provide to Davy’deo while accessing or using the Game, and does not apply to any information that Davy’deo has received, obtained or may obtain ²you from the Game. If you enter or choose to leave the Game via links to other non-Davy’deo websites or apps, your visits and actions on those websites and apps are not covered by this Data Protection Policy.

1. IDENTITY OF THE DATA CONTROLLER

In this Data Protection Policy, the terms “we,” “us” and “our” are used to designate:

Davy'deo Games Studio

8 Avenue des Bruyères

28130 CHARTAINVILLIERS

France

Hereinafter, “Davy'deo.”

We are the Data Controller, which means that we are responsible for your Personal Data. We only use these Personal Data in a fair, legal and transparent manner in accordance with the data protection laws.

2. THE PERSONAL DATA COLLECTED

By creating or administrating your player account or by using the app or playing the Game, you transmit to us or we collect certain data which may identify you (the “Personal Data”).

Processing purpose	Data collected	Legal basis	Retention period	Examples
Creation and administration of the player account	Pseudonym, e-mail, password, data on progress in the Game, score, identifiers of friends registered on the Game, Facebook photo.	The performance of the agreement	Until the request to delete the account In the event that the account is inactive, deletion under the conditions described in Article 7 of the General Terms of Use.	Management of the player account
Purchases in the “In App” store	Transaction data (item purchased, date of purchase, purchase identification number and purchase amount)	The performance of the agreement	The data relating to the transactions are retained for 5 years for purposes of proof. The supporting accounting documents relating to the execution of an order will be retained for 10 years as of the close of the financial year.	Purchase of a life in order to continue to play
Personalisation of the advertising displayed in the Game	Identifiers of the mobile device, advertising ID, IP address, progress in the Game, scores, “In App” purchases, .	The performance of the agreement Legitimate interest	Until the request to delete the account In the event that the account is inactive, deletion under the conditions described in Article 7 of the General Terms of Use.	Display of advertising allowing the player to win an additional life
Processing of requests to exercise rights	Pseudonym, E-mail, Type of request	Legal obligation	Duration of the processing	Request for the exercise of a right of access, limitation, opposition, etc.
Processing of requests to exercise rights	If necessary, a copy of the identity documents	Legal obligation	The time for processing the request
Player knowledge, statistics and performance	IP address, data on progress in the Game, scores, data on the use of the Game, crash reports, “In App” purchases, session identifier, mobile device identifier.	Legitimate interest	The data are deleted or anonymised upon the deletion of the accounts, which also causes the deletion of the account history.	Internal operations to optimise the Game
Promotion of our services and products	Mobile device identifier	Consent, which you may withdraw at any time	We delete your data for this purpose without delay in the event of a withdrawal of consent or a refusal to receive push notifications. In the other cases, we retain your data for 3 years as from the last contact.	To send you “push” notifications

The mandatory or optional character of the Personal Data that you are requested to provide, as well as the consequences in the event of a lack of response, are indicated by an asterisk (*) at the time of collecting the data.

If you are a US resident, the following provisions apply to you:

Aggregated and Anonymized Data

Davy’deo may take your Personal Data and make it non-personally identifiable, either by combining it with information about other individuals (aggregating your information with information about other individuals), or by removing characteristics (such as your name) that make the information personally identifiable to you (de-personalizing your information). Given the nature of this information, there are no restrictions under this Data Protection Policy upon the right of Davy’deo to aggregate or de-personalize your Personal Data, and Davy’deo may use and/or share with third parties the resulting non-personally identifiable information in any manner in Davy’deo’s sole discretion.

Public Postings

Davy’deo may make message boards, bulletin boards, wikis, and other community services available to you in the Game. Please understand that any information that is disclosed by you in these areas becomes public information. When you disclose such information on a message board, bulletin board, wiki, blog or any other public forum, you do so at your own risk. Davy’deo has no control over its use and you should exercise caution when deciding to disclose your Personal Data or any other information about yourself. The information presented in these areas reflects the views of the individual users or hosts and does not necessarily reflect the views of Davy’deo. Davy’deo reserves the right (but has no obligation) to monitor the use of message boards, blogs or other public forums in the Game.

Children Under the Age of 13 and Under the Legal Age of Majority

Davy’deo does not knowingly solicit or collect information from anyone under the age of thirteen (13) and the Game is directed at persons 15 years of age or older. If you are under age 15, please do not use the Game, and do not provide any Personal Data to us. If you are the parent or guardian of a child under the age of fifteen (15), or the legal age of contract majority, and have authorized your child to use your mobile device, computer or provided a mobile device to such child, Davy’deo urges you to instruct your child never to give out his or her real name, address, phone number, email address or other personally identifying information while in the Game. Davy’deo recommends that the Internet browsing behaviour of any child should be carefully supervised by a responsible adult at all times. There are no applications or devices in the Game which allow for the determination of your age. All information volunteered to Davy’deo will be treated the same as information given by an adult.

If Davy’deo discovers that Personal Data of a child under 13 has been collected without parental or guardian consent, Davy’deo will take reasonable steps to delete such Personal Data, which may require us to delete the child’s account. If you are a parent or guardian of a child under the age of 13 and become aware that your child has provided Personal Data to Davy’deo, please contact us at support@davydeogamesstudio.com.

For California residents only

If you are a California resident under the age of 18, California Business and Professions Code Section 22581 permits you to request and obtain removal of content or information you have publicly posted. To make such a request, please send an email with a detailed description of the specific content or information to support@davydeogamesstudio.com. Please be aware that such a request does not ensure complete or comprehensive removal of the content or information you have posted and that there may be circumstances in which the law does not require or allow removal even if requested. For example, Davy’deo may retain the content or information for our own internal records, or potentially a third party we do not own or control may copy the posting and repost it elsewhere.

3. Digital Will

In accordance with the Law for a Digital Republic of 7 October 2016, you have the right to define directives concerning the retention, deletion and communication of the data after your death.

In order to exercise this right, you may send your directives to the following address:

Davy'deo Games Studio

8 Avenue des Bruyères

28130 CHARTAINVILLIERS

France

If you are a US resident, this Section does not apply to you.

4. RECIPIENTS OF YOUR PERSONAL DATA

In connection with your use of the Game, your Personal Data may be transmitted to third parties:

Transmissions of data to other players

In the context of the Game, your pseudonym and your photo may be accessible to other players, particularly in order to establish player classifications.

Transmission of data to our sub-contractors for the Game's needs

The Personal Data that we collect may be transmitted to our commercial partners or our suppliers in order to perform the objectives set out in Article 2, for example in order to allow you to make and receive In App purchases.

You may access the Privacy policy of our payment partners by clicking the following link:

· For Google Store: https://policies.google.com/privacy;

· For Apple Store: https://www.apple.com/legal/privacy/en-ww/.

We also use PlayFab, a service provided by Microsoft, for the creation of your player account, the storage of your data on progress in the Game, the number of gold coins purchased, your scoreboards, as well as the list of your Facebook friends. In this context, your data may be collected and analysed by PlayFab.

To access the full privacy policy of PlayFab's services, you may click on the following link: https://privacy.microsoft.com/en-us/privacystatement.

We also use GetSocial, a service provided by the company Keywords Studios Netherlands B.V., for the creation of the social section (storage of your scoreboards, list of your Facebook friends, referral program, messages), the storage of your data on progress in the Game, as well as your scoreboards. In this context, your data may be collected and analyzed by the GetSocial.

To access the full privacy policy of GetSocial’s services, you may click on the following link: https://www.getsocial.im/legal/#privacy-information-for-users.

Transmission of data for the dissemination of advertising in the Game

· Unity

Your data may be processed by our partner, Unity, acting in the capacity of data controller and under its entire responsibility, in order to obtain awards in the Game.

In this regard, the following data may be collected: IP address, identification of the mobile device, events and actions undertaken in the Game (level, number of credits, time necessary to win these credits, meta-data on communications in the Game and the value and details of the purchases), if you click or press on an advertisement for a new game, if you look at the advertising or if you play a game frequently, if other persons who play a game like yours have downloaded a particular new game, and if you download and install a new game that you see announced.

In order to access the confidentiality policy of our partner, Unity, you may click on the following link: https://unity3d.com/legal/privacy-policy.

· AdMob

Your data may be processed by our partner, Google, in order to provide its service AdMob, acting in the capacity as data controller and under its entire responsibility.

The following data may be collected: browser, apps or device unique identifier, the types and settings of the browser, the type and settings of the device, the operating system, data concerning the mobile network (such as the name of the operator and the telephone number) and the version number of the application, information concerning the interactions between the applications, browsers, devices and Google services, such as the IP address, the error reports, the activity of the system as well as the date, time and originating URL of the requests.

In order to access the confidentiality policy of our partner, Google, you may click on the following link: https://policies.google.com/privacy

· Audience Network

Your data may be processed by our partner, Facebook, in order to provide its service Audience Network, acting in the capacity as data controller and under its entire responsibility.

The following data may be collected or processed: the content that you and other persons provide in connection with your use of the Facebook products, such as the content that you share or create, the content that you consult, the Facebook products that you use as well as information concerning your devices, such as the attributes of your devices, your activity on the device, your unique identifiers related to games, apps or devices you use, signals and data from the settings of the device.

In order to access the confidentiality policy of our partner, Facebook, you may click on the following link: https://www.facebook.com/about/privacy/

If you are a US resident, the following provisions apply to you:

As set forth above, Davy’deo shares information about you, including your Personal Data, with the third-party Internet-based advertising companies set forth in this Section. To learn more about third-party internet-based advertising and how you can opt-out of sites using it, you can visit www.networkadvertising.org and www.aboutads.info/choices. Additionally, users of mobile devices can follow the below instructions to opt-out:

Android Users

Open your Google Settings app from your app drawer, tap “Ads” and select “Opt out of interest-based ads.”

Google Account Users

For opting out via Google, regardless of device: See Google’s instructions for how to do click on the following – Google Ads Help.

iOS Users

Open the Settings app, select “Privacy,” scroll to the bottom and select “Advertising,” and tap to turn on “Limit Ad Tracking.”

Transmission of data in order to establish statistics

Your data may be processed by our partners in the capacity of data controller and under their entire responsibility in order to establish statistics concerning the use of the Game, crashes, In App purchases, scores, registrations and progress in the Game. Our partners may also provide audience analysis tools, particularly in order to help us to improve and optimise the Game.

In order to access the confidentiality policy of our partners, Unity,Firebase, PlayFab, GetSocial, AppsFlyer, you may click on the following links:

· For Unity : https://unity3d.com/legal/privacy-policy ;

· For Firebase: https://firebase.google.com/support/privacy/?authuser=0 and https://policies.google.com/privacy;

· For PlayFab: https://privacy.microsoft.com/en-us/privacystatement.

· For GetSocial: https://www.getsocial.im/legal/#privacy-policy

· For AppsFlyer: https://www.appsflyer.com/privacy-policy

Transmission of data for court or legal reasons:

· to our regulatory authorities, the authorities responsible for the application of the law or the prevention of fraud, as well as our advisors (including attorneys and statutory auditors), the courts, any authorised organisation, with the purpose of investigating any real or suspected criminal activity or other regulatory or legal questions or matters, etc.;

· if we have the obligation to disclose or share your Personal Data in order to comply with any legal obligation or in order to have observed or applied our user conditions and other agreements; or to protect the rights, the ownership or the security of Davy’deo, our clients or any third party;

· If you are a US resident, the following provisions apply to you:

o in the event that a petition for relief is filed under U.S. Bankruptcy laws for or against Davy’deo or if Davy’deo becomes subject to an order of appointment of a trustee or receiver;

o Davy’deo cooperates with law enforcement agencies in identifying those who may be using the Game (or any part thereof) for illegal activities. Davy’deo also reserves the right to report any suspected illegal activity to law enforcement individuals or to entities for investigation or prosecution.

Transmission of data for reasons connected with Davy’deo:

· in the event of a merger, acquisition of our activities or assets or other similar event, to a potential purchaser of our activities or assets;

· to our legal and other advisors in connection with court proceedings in order to assert or apply our rights on the basis of any agreement

5. SECURITY AND STORAGE OF YOUR PERSONAL DATA

When you have chosen a password in order to create an account on the Game, you are responsible for the confidentiality of this password. We ask that you not share this password with anyone.

Unfortunately, the transmission of information via the Internet is not entirely secure. Although we do our best to protect your Personal Data, we cannot guarantee the security of your Internet connection; thus this transmission is made at your own risk.

We are in compliance with the rules for confidentiality and security of the GDPR. We use strict security procedures and mechanisms and use reliable service providers in order to prevent any unauthorised access, including the updating of security correctives, to the extent possible, and by constantly searching for new ways to secure the data.

If you are a US resident, the following provisions apply to you:

Davy’deo reserves the right to monitor all network traffic to the Game to identify and/or block unauthorized attempts or intrusions to upload or change information or cause damage to any part or all of the Game in any manner. Anyone using any of the Game expressly consents to such monitoring.

Please be aware that no data transmission over the Internet or which is stored on a computer or device connected to the Internet can be guaranteed to be 100% secure, so while Davy’deo strives to protect your Personal Data, we cannot ensure or warrant the security of any information that you voluntarily give to us.

Transfers outside of the European Economic Area

For reasons of efficiency, certain of our sub-contractors or partners acting in the capacity of data controller are located outside of the EEA.

We take all reasonably necessary measures to ensure that your Personal Data are processed in full security and in accordance with this Data Protection Policy.

In particular:

· Certain suppliers are certified by the mechanism for data protection applicable in the United States, the Privacy Shield. For more details concerning this mechanism, please consult the following link www.privacyshield.gov;

· If these suppliers are not certified, we have concluded with them standard contractual clauses that are approved by the European Commission in order to ensure the correct processing and the security of your Personal Data. For more details concerning these clauses, please consult the following link:

https://eur-lex.europa.eu/legal-content/FR/TXT/HTML/?uri=CELEX:32010D0087&from=FR

6. EXERCISE OF YOUR RIGHTS

In accordance with the GDPR, you have a right of access, rectification, limitation and, if necessary, the right to delete your Personal Data. You also have the right to portability of the data.

You also have the right, for legitimate reasons, to oppose the processing of the Personal Data concerning you.

You have the right to request access to your Personal Data.	You have the right to request the confirmation of the processing of your Personal Data, access to these Personal Data (by the provision of a copy) and other information concerning the manner in which we process your Personal Data.
You have the right to request that we rectify your Personal Data.	You have the right to request that we rectify your Personal Data if they are inaccurate or incomplete.
You have the right to request that we erase your Personal Data.	Your have the right to request that we erase or delete your Personal Data when there is no reason for us to continue to process them. This right applies if we no longer have a need to use your Personal Data, if you withdraw your consent to the processing of specific categories of your Personal Data or if you oppose the manner in which we process your Personal Data (see the section “You have the right to oppose the processing of your Personal Data” below).
You have the right to request that we limit the processing of your Personal Data.	You have the right to request that we limit the processing of the Personal Data that we hold with regard to you. This right applies when: - you believe that these Personal Data are incorrect, - the processing is illicit and you prefer that we block the processing of your Personal Data rather than erase them, - when we no longer need to use your Personal Data for the purposes for which we collected them, but they are still necessary in order to assert, exercise or defend rights in court, - you wish to verify the legitimate reasons we are pursuing and whether they prevail over yours.
You have a right to portability.	You have the right to obtain from us and to re-use your Personal Data (in a structured format which is widely used and machine readable) in order to re-use them for your own purposes in connection with other services. This allows you to be able to easily transmit the Personal Data to another organisation or to request us to do this for you.
You have the right to oppose the processing of your Personal Data.	You have the right to oppose the processing of your Personal Data on the basis of our legitimate commercial interests, unless we are able to demonstrate that, overall, our legitimate interests prevail over your rights or if we need to continue to process your Personal Data in order to establish, undertake or defend in the context of court actions. However, you also have the absolute right to oppose the processing of your Personal Data for direct marketing purposes.
You have the right not to be subject to automated decisions.	You have the right to oppose the adoption of any automated decision, including profiling, when the decision has a legal or significant impact for you.
You have the right to withdraw your consent.	You have the right to withdraw your consent to the processing of your Personal Data at any time. You may generally do this by unsubscribing to communications that you no longer wish to receive. We provide instructions for unsubscribing in our communications.

You may exercise these rights, upon presentation of a copy of your identification document, by simple written request sent by e-mail to the following address: support@davydeogamesstudio.com.

We will respond to any request received from you within a period of one month following the date of the request. If your request is not sufficiently precise or does not contain all of the information allowing us to respond to your request, Davy’deo may request that you provide additional information.

If the data processing concerns processing carried out by our partners in the capacity of data controller, you must directly contact this service provider in accordance with the conditions indicated in its confidentiality policy.

You also have the right to file a claim with the national data protection agency. In France, this authority is the Commission Nationale de l'Informatique et des Libertés (CNIL) (www.cnil.fr).

Moreover, you also have the right to rectify certain of your Personal Data directly in your personal space using the Options in the Game.

7. Cookies

We may deposit various cookies on your terminal when you use the Game for analysis purposes and in order to improve the Game and in order to present advertising that may interest you.

What is a cookie?

A “cookie” is a small text file placed in your browser software which facilitates browsing on our Internet Site.

If you are a US resident, the following provisions apply to you: Cookies may be either permanent or temporary. Davy’deo may use both temporary and permanent cookies. A temporary or “session” cookie is placed on your computer or mobile device during your visit to certain parts of the Game and is deleted when you exit your Internet browser, the mobile application, and/or turn off your computer or device. A permanent or “persistent” cookie means that the cookie stays on your hard drive or mobile device until you delete it. You can delete Davy’deo’s permanent cookie at any time by following the instructions contained in your browser’s help file, or by contacting the company providing your browser’s or mobile device’s technical support.

We may use:

· Analysis cookies: in order to adapt the Game to the requirements of the players, we analyse the activity of our players. These cookies help us to improve our services in order to offer you the best possible game experience.

No.	Name	Purpose	Retention period
1	Google analytics _ga, _gid	Site consultation statistics	1 year

If you do not wish Google Analytics to collect or use your information, you may unsubscribe on the following page: http://tools.google.com/dlpage/gaoptout?hl=None

· Third party cookies: these cookies are used in order to improve the interactivity of the Game. These third parties must be considered to be solely responsible for any violations of the applicable legislation or a contractual obligation which may result from the deposit of cookies. Davy’deo does not have access to or control over the information provided by these cookies. This information is solely subject to the authority of the third parties and is controlled according to their confidentiality policy. This Game relies on several services offered by third party sites, including in particular:

o the connection buttons (Facebook);

o the advertising services (Unity, Google AdMob).

In order to manage the cookies, please refer to the cookie management settings of your browser. The procedures are described in the Help menu of the software:

· For Internet Explorer™: click here

· For Safari™: click here

· For Chrome™: click here

· For Firefox™: click here

· For Opera™: click here

8. IF YOU ARE A CALIFORNIA RESIDENT, THE FOLLOWING PROVISIONS APPLY TO YOU: CALIFORNIA NOTICES

Davy’deo does not currently have the capabilities to recognize the Do Not Track signals from Internet browsers. Therefore, any selection you make within your Internet browser will not be applied to the Game. For more information regarding Do Not Track you can visit www.allaboutdnt.org.

Section 1798.83 of the California Civil Code requires select businesses to disclose policies relating to the sharing of certain categories of your Personal Data with third parties. If you reside in California and have provided your Personal Data to Davy’deo, you may request information about Davy’deo’s disclosures of certain categories of Personal Data to third parties for direct marketing purposes. Such requests must be submitted to Davy’deo at one of the following addresses: support@davydeogamesstudio.com Attention : Support department.

Within thirty (30) days of receiving such a request, Davy’deo will provide a list of the categories of Dersonal Data disclosed to third parties for third-party direct marketing purposes during the immediately preceding calendar year, along with the names and addresses of those third parties. This request may be made no more than once per calendar year. Davy’deo reserves the right not to respond to requests submitted other than to the address specified in this Section, requests not labeled or sent properly, or requests that do not have complete information.

9. IF YOU ARE A US RESIDENT, THE FOLLOWING PROVISIONS APPLY TO YOU: OPT-OUT OF Davy’deo COMMUNICATIONS/NOTIFICATIONS

You may choose to opt-out of receiving electronic communications from Davy’deo. To opt-out of non-transactional electronic communications from Davy’deo, please contact Davy’deo at support@davydeogamesstudio.com (subject line: “Opt-Out Email Communications”) to request that you be unsubscribed from any of Davy’deo ‘marketing emails. You must provide your name and email address(es), so that Davy’deo can work towards stopping you from receiving such communications.

In addition, you may manage your receipt of marketing and non-transactional communications by clicking on the “unsubscribe” link located on the bottom of any such communication. Davy’deo will use commercially reasonable efforts to process such requests in a timely manner.

Davy’deo may also deliver notifications to your mobile device (i.e., push notifications). You can disable these notifications by deleting the relevant App or by changing the settings on your mobile device.

You can opt-in to receive promotional, marketing, and special offer text messages from Davy’deo. Text messages are auto-dialled. No consent is required to send text messages regarding any purchase or service or item. You can opt-out of marketing text messages by sending STOP to the number that sent the marketing text or by following the directions sent back to you when you sign up.

You should be aware that you cannot opt-out of receiving transaction related communications, including regarding purchases, provision of services, and customer support.

10. IF YOU ARE A US RESIDENT, THE FOLLOWING PROVISIONS APPLY TO YOU: CONTACT US

If you have any questions about this Data Protection Policy, you may contact Davy’deo by email at support@davydeogamesstudio.com, or by mail at

Davy'deo Games Studio

8 Avenue des Bruyères

28130 CHARTAINVILLIERS

France

11. MODIFICATIONS TO THE Privacy POLICY

This Data Protection Policy may be modified at any time. In the event of a modification, we take all the measures necessary in order to communicate to you any change made to this Data Protection Policy.

If you are a US resident, the following provisions apply to you:

Davy’deo reserves the right to make changes to any terms of this Data Protection Policy at any time, however, Davy’deo shall provide notification to you in advance of any changes becoming effective, such as by posting a notification on or in the Game or via email if you have provided Davy’deo with your email address. If you continue to access and/or use any of the Game after the effective date of such changes, then such access and/or use will be deemed an acceptance of and an agreement to follow and be bound by the terms as changed. The revised Data Protection Policy supersedes all previous notices or statements regarding the Game. For this reason, Davy’deo encourages you to review this Data Protection Policy any time you access or use the Game, and Davy’deo recommends that you print out a copy for your records.

This Policy was revised and updated for the last time on 16 January 2021.