Effective Date: July 1st, 2020
● The ways we collect personal data about you and why we do so
● How we use your personal data, and
● The choices you have about your personal data.
If you have questions about data protection, or if you have any requests for resolving issues with your personal data, we encourage you to primarily contact us through the game so we can reply to you more quickly.
Name of contact: IsCool Entertainment
Address: 43 rue d’Aboukir, 75002 Paris, France
In order to ensure compliance with the applicable provisions and in accordance with its regulatory obligations, IsCool Entertainment has appointed a Data Protection Officer (DPO). You can write to him at the following address:
Hachette Livre (Iscool Entertainment) for the attention of the DPO,
58, rue Jean Bleuzen, CS 70007, 92178 – Vanves Cedex
THE DATA WE COLLECT
Data that you agree to provide to us (these data may differ depending on the games and the services):
● Your user name
● Information entered on the profile (such as the photo and first name of your profile)
● Your messages to the Service (such as chat logs and player support tickets)
● Other data you choose to give us (such as data necessary to identify a lost account, namely the game identifier created specifically for the game)
Data we collect for the pruposes of our legitimate interest (these data may differ depending on the games and the services):
● Data about your account and game progress
● Your mobile device identifiers (your IDFA or GAID)
● Data we collect via cookies and similar technologies after obtaining your consent to the deposit of these cookies
● General location data (game language and country)
● Data about your use of the Service, such as gameplay data and your interactions with other players inside the Service (such as messages exchanged with other players)
For the pruposes of our legitimate interest, we also create an IsCool Entertainment specific ID for you when you use the Service. When we do, this ID is available in the profile section.
Data we collect from our partners (these data may be different depending on the game and the service):
● Data we receive if you link a third party tool with the Service (such as Facebook, Google, Apple Game Center)
● Data to fight fraud (such as refund abuse in games or click fraud in advertising)
● Data from platforms that the games run on (such as those used to verify payment)
● Data for advertising and analytics purposes, so we can provide you a better Service
WHY DO WE COLLECT YOUR DATA
To make the Service work.
We process data necessary to (depending on the game and the service):
● Create accounts and allow you to play our games and use our Service
● Operate the Service (creating an account to play applies to Belote Multiplayer, Wordox, Crazy 8 and Is Cool games – other games do not require the creation of a personal account)
● Verify and confirm payments
● Provide and deliver products and services you request
● Send you Service-related communications
To make the Service more suitable for our players.
To provide a great Service to our players, we have a legitimate interest to collect and process necessary data to (depending on the game and the service):
● Update and develop player profiles
● Develop and improve the Service and player experience
● Manage our relationship with you
● Provide social features as part of the Service
● Customize your Service experience
● Respond to your comments and questions and provide player support
● Offer you personalised commercial offers in the Service
● Send you personalised notifications
● Enable you to communicate with other players
To show personalized advertisements.
To show you personalized advertisements in the Service, we have a legitimate interest to process necessary data to (depending on the game and the service):
● Transfer your phone advertising identifier to partner advertising platforms subject to having obtained your prior consent
For information on how to opt-out from personalized advertisements, see section ‘Your rights and options’ below.
To improve the service.
We collect data for statistical purposes in order to improve the service and our marketing campaigns. The data we use for statistical purposes is essentially game data or navigation in the service. It does not contain any personal data other than the advertising identifier of your phone that we use to measure the performance of our marketing campaigns.
To keep the Service safe and fair.
In order to keep the Service and its social features safe and fair, to fight fraud and ensure acceptable use otherwise, we have a legitimate interest to process necessary data to (depending on the game and the service):
● Analyze and monitor use of the Service and its social features
● Moderate chats either automatically or manually
● Take action against fraudulent or misbehaving players
● To analyze, profile, and segment.
In all of the above cases and purposes, we may analyze, profile and segment all collected data.
WHO CAN SEE YOUR DATA
Apart from IsCool Entertainment, your data can be accessed and processed by others in the following situations:
OTHER PLAYERS AND USERS.
Social features are a core component of some of our games, including Belote Multiplayer, Wordox, Crazy 8 and Is Cool. Other players and users may, for example, see your profile data, in-game activities and read the messages you have posted.
PARTNERS WORKING FOR ISCOOL ENTERTAINMENT.
IsCool Entertainment has partners to perform services for us. These partners process your data only at and according to IsCool Entertainment´s instructions to provide the Service, such as hosting, player support, advertising, analytics and fraud prevention. A list of these partners is available below.
Other companies and public authorities.
In order to combat fraud and illegal activity, we may exchange data with other companies and organizations and provide it to administrative and judicial authorities in response to lawful requests.
We may also disclose your data based on your consent, to comply with the law or to protect the rights, property or safety of us, our players or others.
Advertising and Social Media partners.
The Service includes features from our partners, such as social media interaction tools and in-game advertising. A list of these partners is available below. These partners may access your data and operate under their own privacy policies. We encourage you to check their privacy policies to learn more about their data processing practices.
INTERNATIONAL DATA TRANSFERS
Our Service is global by nature and your data are currently stored in the European Union and the United States based on data and games. Because different countries may have different data protection laws than your own country, we take steps to ensure adequate safeguards are in place to protect your data as explained in this Policy.
YOUR RIGHTS AND OPTIONS
Opt-out of marketing emails and other direct marketing.
You may opt-out of receiving promotional communications, such as marketing emails from us by following the instructions in such communications. To date, we do not operate any email campaigns. You may opt-out from device notifications on your mobile phone communication by deactivating notifications in your mobile device settings.
Deactivating personalized advertising.
On desktop services (games on Facebook), you can opt-out from targeted advertising by deleting your cookies.
Your rights with regard to the personal data we hold about you.
In application of the regulations in force, by proving your identity, you can exercise the following rights:
̶ the right to access your Data;
̶ the right to have your Data corrected;
̶̶ the right to have us erase your Data and Personal information;
̶ the right to obtain the portability of your Data;
̶ the right to limit the processing of your Data;
̶ the right to object to the processing of your Data.
To exercise your data protection rights, you may send a written request to our data protection officer by post or email. The method to contact us can be found in the CONTACT US section at the top of this page.
If necessary, you can also refer to a supervisory authority.
Define post-mortem guidelines
You can define guidelines for the fate of your Data after your death (conservation, erasure and communication), with a trusted digital third party certified by the CNIL for general instructions or with IsCool Entertainment for instructions specific to the Data that you entrust to us.
COOKIES AND SIMILAR TECHNOLOGIES
HOW DO WE PROTECT YOUR DATA
In order to help ensure a secure and safe player experience, we are continuously developing and implementing appropriate physical, technical and organizational security measures to protect your data against loss, destruction, alteration, disclosure or unauthorized access.
We retain your data for as long as your account is active or as needed to provide you the Service. We periodically delete unused game accounts and we regularly review and de-identify unnecessary data. In general, we delete all data from accounts that have been inactive for at least twenty-four (24) months on Belote Multiplayer, Wordox, Crazy 8 and Is Cool. This means that on these games, after twenty-four (24) months of inactivity, we will not be able to restore your account to its state of last activity.
Please note that if you ask us to remove your personal data, we will retain some of your data as necessary for our legitimate business interests, such as to comply with our legal obligations, resolve disputes, and enforce our agreements. Note that any anonymised data may be retained as well.
We do not knowingly collect or solicit personal data about or direct or target interest based advertising to anyone under the age of sixteen (16) or knowingly allow such persons to use our Services. If you are under sixteen (16), please do not send any data about yourself to us. No one under the age of 16 may provide any personal data. If we learn that we have collected personal data about a child under age sixteen (16), we will delete that data as quickly as possible. If you believe that we might have any data from or about a child under the age of sixteen (16), please contact us.
LIST OF PARTNERS WHO MAY HAVE ACCESS TO YOUR DATA OR MAY PROCESS THEIR ACTIVITY USING YOUR DATA