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Policy Privacy

 

Introduction

This Privacy Policy describes the practices of SARL GLOBA (“PlayGate”, “The Company”, “We”) regarding information required from users who access our website at playgateapp.com (“Site”) to our PlayGate application (“Application”), or share personal information with us (collectively: “User” or “Users”).

Responsible authority regarding data protection laws, in particular the General Data Protection Regulation (GDPR): SARL GLOBA.

 

Reasons for data collection

The processing of your personal information (meaning any information that could potentially allow you to be identified by reasonable means; hereinafter "Personal Information") is necessary to provide our services to you, protect our legitimate interests and comply with the regulatory obligations (legal and financial) to which we are subject.

When you use the Site or Application, you agree to the collection, storage, use, disclosure and other uses of your Personal Information as provided in this Privacy Policy.

We encourage our Users to read the Privacy Policy carefully and use it to make informed decisions.

 

What information do we collect?

We collect two types of data and information about our Users.

The first type includes non-identified and non-identifying information relating to one or more Users, and which may be made available to us or collected as a result of their use of the Site or Application (“Non-personal Information”). We do not know the identity of the Users from whom this non-personal information was collected. We may collect this non-personal and anonymous data on the use of the application in order to allow us to improve the user experience and to add new functionalities (information such as the number of contacts, calls, actions carried out within the games, time spent). This information cannot identify your device or your identity and is completely anonymous. In addition, this information is for internal use only and will not be shared.

We may also collect information about your activity on the Site (e.g. pages viewed, online browsing, clicks, actions, etc.).

The second type includes Personal Information, i.e. individual identification information, which identifies an individual or which is likely, by reasonable means, to allow the identification of an individual. This information includes:

  • Registration information: To use our application it is necessary to enter a name (nickname or other, no verification will be made) and an email address is optional in order to be able to move your account to another device. We do not knowingly collect any other personal information. User profiles are private and cannot be searched or displayed publicly. To add a contact it is necessary to know the "PlayGate code" of the contact and to send an invitation which must be approved by the parents of the contact if the latter is a minor.
  • Device Information: We collect Personal Information about your device that includes unique identifiers (e.g. UUID) and other information relating to your activity on the Site or Application.

 

How do we receive information about you?

Your Personal Information is collected in several ways:

When you voluntarily provide your personal data by registering on our Site or application;

When you use or access our Site or Application in connection with your use of our services;

From third-party vendors, services, and public registries (e.g., traffic analytics providers).

We work with Google Analytics to collect this anonymous data. Their privacy policy can be viewed here:

https://policies.google.com/privacy?hl=fr

 

Permissions on the device to access your personal data

 

Depending on the User's specific device, the Application may request certain permissions to access User's Device Data, as described below.

 

By default, these permissions must be granted by the user before the respective information can be viewed. Once the authorization has been granted, it can be revoked at any time by the User. In order to revoke these permissions, users may refer to device settings or contact the owner for assistance at the contact information provided herein.

The exact procedure for controlling app permissions may depend on the user's device and software.

 

Please note that revoking these permissions may impact the proper functioning of this Application.

 

If the User grants one of the permissions listed below, the respective Personal Data may be processed (i.e. viewed, changed or deleted) by this Application.

 

Camera permission

Used to access the camera or capture images and videos from the device.

 

Microphone authorization

Allows access and recording of microphone audio from the user's device.

 

How is this information used? With whom do we share this information?

We do not rent, sell, or share User information with third parties except as described in this Privacy Policy.

We may use information for the following reasons:

 

-To communicate with you by sending you messages regarding our services, providing you with technical information and responding to any customer service questions you may have;

-Communicate with you and inform you of the latest updates and new services;

-After visiting our Site we may show you advertisements on the Internet for our products (see the “Advertisements” section for more);

-Promote our websites, Apps and our products (see the “Marketing” section for more);

-Conduct statistical and analytical surveys to improve the Site or Application.

 

In addition to the various uses mentioned above, we may transfer or disclose Personal Information to our subsidiaries, affiliates and contractors.

In addition to the reasons mentioned in this Privacy Policy, we may share Personal Information with trusted third-party providers (which may be in different jurisdictions around the world), for the following reasons:

 

  • To host and operate our Site and Application:
  • To provide you with our services, including a personalized display of our Site and Application, video call functionality;
  • Store and process such information on our behalf;
  • Present advertisements to you and help us evaluate the success of our advertising campaigns on the Internet (no advertising in the Application)
  • Provide you with marketing offers and promotional content relating to our Site, Application and our services;
  • Carry out research, technical or analytical diagnoses;
  • During a video call, the profile picture of the user is displayed on the called contact's device

 

We may also release information if we have a good faith belief that release of such information is helpful or reasonably necessary to: 

(i) comply with applicable law, regulation, legal process, or government request; 

(ii) enforce our policies (including our Privacy Policy), including investigations of potential violations thereof; 

(iii) investigate, detect, prevent or take action against suspected fraud or security issues; 

(iv) establish or exercise our rights to defend against any legal claims; (v) prevent harm to the rights, property, or safety of our business, our users, you, or any third party; or 

(vi) for the purposes of cooperating with law enforcement, and/or where we believe it is necessary, to exercise intellectual property or other legal rights

 

Video Calls

Video calls between Users can be made directly between them with WebRTC technology and its security protocols with encryption of audio or video streams or by transiting through a partner platform before joining the other User in order to improve responsiveness and the quality of the call by compressing for example the audio and video streams so that they use less bandwidth for Users with a weak internet connection. These video calls are neither viewed nor recorded.

The partner platform is Agora.io, you can consult their Privacy Policy at: https://www.agora.io/en/compliance/

This partner is certified:

  • ISO/IEC 27001: INFORMATION SECURITY MANAGEMENT
  • ISO/IEC 27017: Information technology — Security techniques — Code of practice for information security controls based on ISO/IEC 27002 for cloud services
  • ISO/IEC 27018: Information technology — Security techniques — Code of practice for the protection of personally identifiable information (PII) in public cloud computing acting as a processor of PII

 

A SOC 2 audit report was also issued. It is designed to provide customers of service organizations, management, and users with assurance about the adequacy and effectiveness of the service organization's controls that relate to the security, availability, integrity of the treatment, confidentiality and / or confidentiality.

 

Copyright and image rights

The user (if of the age of legal majority) or his legal representative agrees to share the image rights related to the images used for the profile and which can be saved on our servers or those of our partners. They undertake to protect SARL GLOBA against any claim related to the use and storage of these photographs.

 

Minors

We understand the importance of protecting children's privacy, especially in an online environment. The Site was not designed for use by children. Under no circumstances do we authorize the use of our services by minors without the prior consent or authorization of a parent or legal guardian. We do not knowingly collect Personal Information from minors. If a parent becomes aware that their child has provided us with Personal Information without their consent (or if a guardian becomes aware that the child in their care has provided us with Personal Information without their consent), he or she must contact us at: aide@playgateapp.com.

 

User rights

You can ask:

  1. Receive confirmation that we are processing personal information about you (or notice that we are not processing your personal information, if applicable) and access your stored personal information, as well as additional information.
  2. Receive a copy of the personal information you have voluntarily provided to us in a structured, commonly used, and machine-readable format.
  3. Request rectification of your personal information that we store.
  4. Request deletion of your personal information.
  5. Object to the processing of your personal information.
  6. Request that we restrict the processing of your personal information.
  7. File a complaint with a supervisory authority.

Please note, however, that these rights are not absolute and may be subject to our own legitimate interests and regulatory requirements.

If you would like to exercise any of the above rights or receive more information, please contact our Data Protection Officer using the information provided here: aide@playgateapp.com.

 

Conservation

We will retain your personal information for as long as necessary to provide our services, and as necessary to comply with our legal obligations, resolve disputes, and enforce our policies. The retention periods will be determined according to the type of information collected and the purpose of its collection, taking into account the requirements applicable to the situation and the need to destroy obsolete and unused information as soon as possible. Pursuant to applicable laws and regulations, we will maintain records containing customer personal information, account opening documents, communications and any other required information.

We may correct, complete or delete incomplete or incorrect information at any time and at our sole discretion.

 

Cookies

We and our trusted partners use cookies and other technologies in our related services, including when you visit our Site or access our services.

A "cookie" is a small piece of information that a website assigns to your device when you visit the site. Cookies are very useful and their use can have different purposes, including allowing you to navigate between pages efficiently, allowing certain features to be activated automatically, remembering your preferences and allowing you to interact with our Services more quickly and easily. Cookies are also used to ensure that the advertisements you see match your interests and are personalized accordingly, as well as to compile statistical data about your use of our Services.

The Site uses the following types of cookies:

 

  1. "Session cookies" which are stored only temporarily during your browsing session to allow normal use of the system, and are deleted from your device when you close the browser;
  2. “Persistent cookies” which are only read by the Site, which are saved on your computer for a fixed period and are not deleted when the browser is closed. These cookies are used when we need to recognize you on repeat visits, for example, to allow us to remember your preferences the next time you log in;
  3. “Third-party” cookies which are set by other online services that manage content on the page you are viewing, for example, by third-party analytics companies that monitor and analyze our web access.

Cookies do not contain any information that identifies you personally. You can delete cookies by following the instructions in your device preferences. Please be aware, however, that if you choose to disable cookies, some features of our Site may not function properly and your online experience may be limited.

 

 

Collection of information by third parties

Our policy only addresses the use and disclosure of information we collect from you. To the extent you disclose your information to other parties or sites on the Internet, different rules may apply to its use or disclosure. Accordingly, we encourage you to read the terms of use and privacy policy of each third party to which you voluntarily disclose your information.

This Privacy Policy does not apply to the practices of companies that we do not own or control, or individuals that we do not employ or manage, including any third parties to whom we may disclose your information as set forth in this Privacy Policy.

 

How do we protect your information?

We take great care in implementing and maintaining the security of the Site, Application and your information. Although we implement reasonable measures to safeguard information, we cannot be held responsible for the acts of persons who gain unauthorized access to or abuse our Site or Application, and we make no guarantee, formal, implied or other, to prevent such access.

 

Transfer of data outside the EEA

Please note that some data recipients may be located outside the European Economic Area (EEA). In such cases, we will transfer your data to such countries only as approved by the European Commission providing the adequate level of data protection, or we will enter into legal agreements guaranteeing an adequate level of data protection.

 

Advertising

We may use third-party advertising technology to transmit advertisements when you access the Site. This technology uses information about your use of the Services to transmit advertisements to you (for example, by placing third-party cookies on your web browser).

You can opt out of many third-party ad networks, including those operated by members of the Network Advertising Initiative (“NAI”) and Digital Advertising Alliance (“DAA”). To obtain more information from NAI and DAA members about this practice and your choices regarding these companies' use of this information, including how to opt out of third-party advertising networks operated by NAI and DAA members, please visit their respective websites:  http://optout.networkadvertising.org/ and  http://optout.aboutads.info/.

 

Marketing

We may use your Personal Information, including your name, email address, telephone number, etc., ourselves or through subcontractors to provide you with promotional content regarding the services which we believe might interest you.

Out of respect for your right to privacy, we include in this promotional content the means to opt out of receiving new promotional offers from us. If you unsubscribe, we will remove your email address or phone number from our marketing distribution lists.

Please note that even if you opt out of receiving marketing emails from us, we may send you other types of important communications by email without giving you the opportunity to opt out. These may include customer service messages or administrative notifications.

 

Business transaction

We may share information in the event of a business transaction (e.g. sale of a significant part of our business, merger, consolidation or sale of assets). In the cases mentioned above, the beneficiary or the acquiring company will assume the rights and obligations as described in this Privacy Policy.

 

Links to other websites

The Site contains links to third-party sites and cannot be held responsible for the privacy policies of these sites. This Privacy Policy applies only to information collected by GLOBA on this Site or Application.

 

Updates or changes to this Privacy Policy

We reserve the right to periodically change or revise the Privacy Policy; material changes will be effective upon posting of the revised Privacy Policy. The last revision date will be available in the "Last Modified" section.

Your continued use of the Platform, following notice of such changes on our website, constitutes your acknowledgment and acceptance of such changes and your consent to abide by them.

 

Contact us

If you have general questions about the Site, the Application or our collection and use of information about you, please contact us at: contact@playgateapp.com.

 

SARL GLOBA registered in France RCS 844 446 518 00012 and its registered office is located at 38 avenue Rouget de l'Isle, 83340 Le Luc.

 

Last Modified: July 06, 2022