Policy on the protection of personal data

 

Effective: November 29, 2021

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We provided real-life mobile apps designed to entertain and provide tools to help in everyday life. To do this, we need information about you. Protecting your privacy is very important to us. We only use your information to the extent that we have a legal basis to do so. This Privacy Policy will help you understand what information we collect, how we use it, and what choices you have when you use one of our applications or use our websites.

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You should also read our Terms of Use which define the contract between you and Sylvain Royal.

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1. Who decides on the use of your Personal Data?

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Sylvain Royal is the data controller responsible for making decisions about how we use your personal information.
 

If you have any questions or comments about this policy, you can:

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• Email us at sroyal_uni@hotmail.com

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2. The information we collect about you and how we use it

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This Privacy Policy covers our use of any information that may or may be used to identify you or your home ("Personal Data"). It does not cover information that cannot be used to identify you ("Anonymous Data").

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We need to collect and use certain Personal Data to provide you with the Services and fulfill the promises we make to you in our Terms of Use:

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• When you register for our Services, you voluntarily provide us with Personal Data by providing it to us, for example when you create an account. We collect and use this information to authenticate you when you create an account and use the Services, to ensure that you are eligible and able to receive the Services, and that you receive the correct version of these Services. This information includes the email address you choose to use on our Services, and the internal account credentials we assign to your account.

• You must have an account with an external provider of compatible single sign-on services to use some of our Services. As such, the Personal Data we collect also depends on the external provider you choose to use, its Privacy Policy, and what your privacy settings for these services allow us to see when you use these services to access Sylvain Royal’s Services.

  • If you choose to link your Facebook account to the Services, we will collect a unique user ID provided by Facebook and your registered Facebook email address.

 

Some external providers may inform you that they make additional information available to us, such as your public profile, when you use their single session services. We do not collect this information from them.

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• We collect and use your actions and achievements in the app, as well as certain information about your mobile device (including device identifiers, its operating system, model and configuration, settings and information about third-party applications or software installed on your device) to operate the Services for you.

• We also use the above information to provide you with technical and customer support.

• You also provide us with Personal Data when you make a purchase through us, when you subscribe to our publications, when you register for a live event, a promotion, or a survey, or when you contact us. Depending on the Services you use, this may include your last name, first name, mailing address, telephone number, country of residence, city of residence, date of birth (if necessary to verify your eligibility), gender, and email address. We use this information to provide you with these Services and to provide you with the appropriate customer support.

• Google may use the advertising ID from the device which the ad is serving to generate interests and demographics and other data may be used to serve better-targeted ads. We, Sylvain Royal, do not have access to this data and don’t store the data.

 

In addition, we have a legitimate interest in – and rely on – using your Personal Data as follows:

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• Use your IP address, the type of browser and operating system you use, the web page you visited before accessing our Services, the pages of our Services you have accessed or the features you have used, the time you have spent on these pages or functions, the links to our Services on which you click, the advertising and device identifiers and the actions you take during the application, your preferences and user settings in the applications and your purchases on our application to understand who uses our Services and how, the advertisements that were displayed on your device, when they were displayed and when you click on them.

• Use your contact information, including your email address, to contact you to provide technical support, and customer support, and to discuss awards.

• Use your internal account ID to assign to your account any user content you choose to submit to Sylvain Royal through Services.

• To provide new or additional functions for our Services.

• Use your actions and achievements in the app, as well as some information on your mobile device (including device identifiers, operating system, model, configuration, settings and information about third-party applications or software installed on your device), to implement anti-fraud and anti-fraud and anti-cheat against the behaviors prohibited by our Terms of Use, to guarantee a fair experience to all participants.

• To make legal or regulatory communications and to establish, exercise or defend legal claims and/or legal claims.

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3. Those with whom we share information

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We will not share the Personal Data we have collected about you, except as described below:

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Information shared with our service providers. We engage external service providers to work with us to administer and deliver the Services. In this context, they will process your Personal Data on our behalf. These external service providers have access to your Personal Data solely for the purpose of providing services on our behalf, in accordance with this Privacy Policy, and we ensure that each of them is contractually bound not to disclose or use your Personal Data for any other purpose. The service providers we use help us:

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• Execute, operate and maintain our mobile applications through a third-party platform and software tools ;

• Perform content moderation and fault analysis ;

• launch email and mobile messaging campaigns  ;

• perform application and marketing analysis  ;

• manage user account registration  ; and

• provide technical and customer support  ;

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Some external service providers may also collect information directly from you (for example, a payment agency may request your billing and financial information) as a Third Party Service in accordance with their own Privacy Policy. These external service providers do not share your financial information, such as your credit card number, with Sylvain Royal, but they may share with us limited information related to your purchase, such as your postal code or zip.

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Information shared with third parties. We share anonymous data with third parties for industry and market analysis. We may share Personal Data with our third-party publishing partners for their direct marketing purposes only if we have your express permission. We do not share Personal Data with other third parties for their direct marketing purposes.

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Information disclosed for our protection and the protection of others. We cooperate with the government and law enforcement authorities or with private entities to enforce and comply with the law. We only share your personal information with government authorities, law enforcement or private entities where we reasonably believe it is necessary or appropriate to: (a) respond to complaints and court proceedings (including subpoenas and court warrants); (b) to protect our property, rights and security, and those of a third party or the general public; and (c) to investigate and stop any activity that we consider illegal, immoral or liable to prosecution.

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Information disclosed during commercial operations. The information we collect from our users, including Personal Data, is a commercial asset. If we are acquired by a third party as a result of a transaction such as a merger, acquisition or sale of assets, or if our assets are acquired by a third party in the event that we cease operations or go bankrupt, some or all of our assets, In particular, your Personal Data will be communicated or transferred to a third party purchaser as part of this transaction.

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4. How your Personal Data is transferred

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Sylvain Royal operates its Services worldwide. Your Personal Data will most likely be transferred and stored in a country outside of your home country, including the United States, for the purposes described in this Privacy Policy. The data protection laws in these countries may not be the same as in your home country

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5. How we protect your Personal Data

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We have put in place appropriate security measures to prevent accidental loss, unauthorized use or access, modification, or improper communication of your Personal Data. We also restrict access to your Personal Data to employees, agents, subcontractors and other third parties who have a professional need to know about it. They will only process your Personal Data on our instructions and are subject to a duty of confidentiality. We have put in place procedures to deal with any alleged breach of the protection of Personal Data and will inform you, as well as any applicable regulator, of such breach when we are legally required to do so.

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6. How long we will keep your Personal Data

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We retain your Personal Data for as long as necessary to provide you with the Services and meet the purposes set out in this Privacy Policy. This is also the case for anyone with whom we share your information and who provides services on our behalf.

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When we no longer need to use your Personal Data and no longer need to keep it to comply with our legal or regulatory obligations, we will remove them from our systems or anonymize them so that they can no longer be associated with you. When deleting Personal Data, we will take commercially reasonable and technically feasible measures to make such Personal Data irrecoverable or impossible to reproduce.

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7. Your rights and choices

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You have certain rights regarding your Personal Data. To exercise these rights, please contact us at the following addresses:

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• sroyal_uni@hotmail.com

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You can :

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• Request access to the Personal Data we hold about you.

• Delete or correct your Personal Data. The easiest way to update your account information is to use your application settings.

• You object to us processing your Personal Data. Some of the Personal Data we hold is necessary to provide you with the Services and to fulfill the promises we make to you in the Terms of Use.

• Ask us to stop using your Personal Data, including for marketing and promotion purposes (but be aware that we may need to use your Personal Data for you to use the Services).

• Transfer your Personal Data to another organization (where technically possible).

• Complaining to a regulator. We would appreciate hearing your concerns directly from you and would prefer that you contact us first.

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The law provides for exceptions to these rights in certain circumstances. If you are unable to exercise any of these rights because of such an exception, we will explain why.

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We offer you choices regarding the collection, use, and sharing of your Personal Data and we will respect the choices you make. Please note that if you decide not to provide us with the Personal Data we request, you may not be able to access all the features of the Services.

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Our goal is to provide the information or complete the result you request within 30 days.

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8. Amendments to this Privacy Policy

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All Personal Data that we collect is processed as part of the Privacy Policy in effect at the time that this information is collected. We may make changes to this Privacy Policy from time to time. You will receive reasonable notice of any material changes.

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9. Third parties

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By using our Services, you can access links to websites and services owned or operated by third parties (each of which is a "Third Party Service"). Any information you provide on or to a Third Party Service or that is collected by a Third Party Service is provided directly to the owner or operator of the Third Party Service and is subject to the owner’s or operator’s Privacy Policy. We are not responsible for the content, confidentiality or security practices and policies of any Third Party Service. To protect your personal information, we recommend that you carefully read the privacy policies of all Third Party Services to which you access.

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10. Communications specific to California residents

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​California law requires us to disclose certain information about your data. We do not sell your Personal Data. The information listed in Section 2 falls into the following categories of the California Consumer Privacy Act (CCPA): identifiers, commercial information, information related to activity on the Internet or other electronic networks, geolocation data and visual information.