Article 1: Preamble

This Privacy Policy Statement informs you of the terms and procedures for the collection, processing and use of your personal data by the company Sylvain Seccia EIRL, registered with the Paris Area Companies and Commerce Register (RCS) under number 449 395 953, (hereinafter the "Company", "Sylvain Seccia EIRL" or "We"/"Us"). This statement also informs you of your data protection rights and obligations when using Sylvain Seccia EIRL websites (the "Websites"), video games (the "Games") and applications (the "Applications") published by the Company for computers or mobile devices and that provide a link to this Privacy Policy.

The Websites, Games and Applications are collectively referred to as the "Services".

Sylvain Seccia EIRL is responsible for collecting personal data.

By accessing or using the Services, you acknowledge having read this Privacy Policy and consent to it.

Article 2: Data Collected

2.1 The information you provide us

When you use our Services, personal data may be requested.

The expression "personal data" denotes any and all information directly or indirectly identifying you, by reference to an identification number or to one or more elements specific to you.

We will not ask you for this information if you are only visiting our Websites.

When personal data are collected, you will be informed whether the information We are asking you to disclose is required or optional, and the possible consequences of not providing the data.

2.1.1 When you create an online savegame account ("Savegame Account"), We ask you to provide the following information: email address.

2.1.2 When you participate in a contest or survey, We may request personal data such as your full name, age, mailing address, and email address.

2.2 Information We collect automatically when you use Services

When you use the Services, We collect information on the Services you use and how you use them:

2.2.1 When you install and use our Games, We collect the following information: game data (data exchange log and history, connection log and history, and generally speaking all data connected to actions performed in the Games), data on your hardware and software configuration (when installing a game and in the event of a modification to your computer's hardware), and IP address.

2.2.2 When you install and use our Applications, We collect the following information: IP address, connection date and time, and information on your mobile device (brand, model, operating system version, the device's unique identifier).

2.3 Ad Networks

Sylvain Seccia EIRL may feature advertising within the Services. The advertisers may collect and use information about you such as:

• performance and game contextual data like your games session activity;
• aggregated and/or de-identified information that is not intended to specifically identify a user; and
• technical information such as device identifier, Advertising ID, and IP address.

Ad Networks may use this information to provide interest-based or targeted advertisements to you.

Article 3: Purpose and Legal Basis

Your personal data may be processed for different reasons and based on different legal bases:

3.1 We use your data because they are necessary for the proper execution of a contract between you and Us. Thus, your data will be processed to:

• create, manage, and monitor Savegame accounts;
  
• allow you to access and use the Services;
  
• send you important information about the Services and any other information in relation to your Savegame Account and the actions performed with it (for example: forgotten password emails messages);
  
• manage claims; and
  
• assist you in the event of technical issues using our Services.

3.2 We use data based on our legitimate interests when such use does not infringe on your rights and freedoms. Thus, your data will be processed to:

• improve our Services, notably to improve Game performance and experience, or manage bugs;
  
• ensure the safety of your Savegame Account; offer you commercial events such as contests;
  
• prevent and detect unusual behavior;
  
• monitor and track in-Game behavior and compliance with the rules set forth in our Terms of Use and all other documents that you agree to when using our Services;
  
• measure the performance of our marketing campaigns.

As part of efforts to combat in-game cheating, automatic decisions may be made based on your interactions with the Services and the data you provide. We may notably limit or suspend your access to our Services (notably through sanctions applied to your Savegame Account) if this automatic processing detects a user or activity that presents, in our opinion, a risk of cheating.

3.3 We process some of your data when it is necessary to comply with our legal obligations (notably to comply with our accounting and fiscal obligations or when the law requires us to retain specific data).

Article 4: Disclosure of Personal Data

Sylvain Seccia EIRL may have recourse to third-party service providers who collect your personal data in Sylvain Seccia EIRL's name and on behalf of Sylvain Seccia EIRL, or with whom Sylvain Seccia EIRL will share your data, in a secure manner, notably with the aim of ensuring the completion of the tasks necessary to execute your order, deliver products, process your payments, ensure management of customer relations, fight payment fraud or even propose surveys.

These providers may be located outside the European Union. Sylvain Seccia EIRL has taken every necessary precaution to ensure that your personal data are sufficiently protected, either under contractual data protection clauses established by the European Commission or by ensuring that these data transfers happen with American companies that adhere to Privacy Shield principles.

Sylvain Seccia EIRL may also communicate your personal data to the appropriate authorities, at their request, in the framework of legal proceedings, legal inquiries, and information requests by the authorities, or to comply with other legal requirements.

Article 5: Cookies

The Websites do not use cookies.

Article 6: Security

The Company takes every appropriate technical and organizational measure, given the nature of the data and the risks inherent in data processing, to preserve a high level of data security, and in particular, to prevent it from becoming distorted or damaged, or from being accessed by unauthorized third parties.

The Company reserves the right to initiate proceedings against any person who attempts to gain access to personal information not concerning him/her.

Article 7: Third-party websites

Hypertext links on the Services may redirect you to third-party sites not belonging to Sylvain Seccia EIRL.

We wish to draw your attention to the fact that the personal data protection polices of these various sites may differ from this Privacy Policy. We advise you, in all cases, to acquaint yourself with the personal data protection policies of each of those sites.

In any case, Sylvain Seccia EIRL cannot be held responsible in the event that the content of such a site or sites breaches the statutory and regulatory provisions in force, or the terms of this Privacy Policy.

Article 8: Your Rights

Except where stipulated otherwise, You may exercise your rights set forth in this article by writing to:

Sylvain Seccia EIRL
133 rue d'aboukir
75002 Paris, France

Out of concern for your privacy and to protection your personal data, We must ascertain your identity before replying to your request. Accordingly, any request to exercise your rights must be accompanied by a copy of a signed identity document.

Your request will be processed as soon as possible, in accordance with the legal provisions in force.

8.1 Access right and portability right: You have the right to obtain confirmation that your personal data are or are not processed by Sylvain Seccia EIRL and, when they are, to access the said data and information pertaining to their processing. You may also, when this is technically feasible, exercise your right to portability.

8.2 Rectification right: You have the right to obtain the rectification of your personal data that may be inexact or incomplete (and that you cannot rectify yourself via the services made available by Sylvain Seccia EIRL).

8.3 Erasure right: We store your personal data as long as it is needed for the purposes set forth in the present policy. If you no longer want Us to process your data, you may ask Us to erase them and close your Savegame Account. Please note, however, that even if you exercise this right, We may retain some data for the following purposes:

• We may retain some of your data to protect our legitimate interests, such as detecting and preventing fraud.
• We may retain and use your data to comply with our legal obligations.

8.4 Right to restrict processing: You have the right to restrict processing of your data in limited circumstances: (i) when you contest the accuracy of your data; (ii) when processing is illicit and you request the restriction of their use instead of their erasure; (iii) when We no longer need your data for processing but when you still need them to establish, exercise or defend rights in court; (iv) when you are opposed to processing by virtue of Article 8.5, during the verification of whether Sylvain Seccia EIRL's legitimate motives prevail over yours.

8.5 Right to object: You may object, at any time and for reasons linked to your individual situation, to the processing of your data when this processing is based on a legitimate interest. If you exercise this right, We will no longer process your data, unless We can show that there are legitimate and imperative reasons for the processing that prevail over your interests, rights and freedoms, or for the establishment, exercise or defense of rights in court.

You may object at any time to the processing of your data for direct marketing purposes. Our emails contain a link to unsubscribe.

Article 9: Data Storage

We store your personal data as long as it is needed for the purposes set forth in the present policy, in compliance with laws and legislation in force. To know your rights to erasure, please see the article on "Your Rights".

Article 10: Update

We reserve the right to amend this Privacy Policy at any time. Consequently, We advise you to refer to our "Privacy Policy" regularly.

Last amended: February 2021

Article 11: Inquiries and Complaints

For any inquiry or complaint relating to our Privacy Policy, you may contact Us in French or in English by postal mail at the following address:

Sylvain Seccia EIRL
61 rue de Lyon
75012 Paris, France

You may also contact our data protection delegate at the same addresses.

If, however, you believe that We have not met your expectations, you may submit a claim with a competent data protection supervisory authority.