PRIVACY POLICY
1. AIM OF THE PRIVACY POLICY
The Privacy Policy represents an ongoing concern for SPARKYCELLS
(hereinafter referred to as SPARKYCELLS) and companies affiliated to
it (mother company, subsidiaries, etc.). The Privacy Policy applies
to all our SERVICES or APPLICATION (App, Game, or website) as listed
in our GTC:
- General Terms and Conditions (GTC)
and hereinafter referred to as THE APPLICATION, THE APP, or
APPLICATION (to refer to a single application), or APPLICATIONS or
SERVICES whenever the plural is required to refer to all of
them.
Whenever the policies must differ from one APPLICATION to another,
it is then explicitly detailed by providing the name of the
APPLICATION and the list of such differences.
The Privacy Policy has for a purpose to ensure the protection of
the private lives of users of the services described hereinafter in
view of current regulations and in particular, Law 78-17 of January
6, 1978 relating to information technology, files and freedom. The
current Privacy Policy is an integral part of the Terms and
Conditions of Use governing the APPLICATIONS provided by
SPARKYCELLS, in particular via third-party social network platforms
(hereinafter referred to as “PLATFORMS”), including all content, all
services and all features accessed via these games and software
applications (hereinafter referred to collectively as SERVICES). In
particular, the current Privacy Policy aims to inform you of the
general policy implemented by SPARKYCELLS for the use of THE
APPLICATION in terms of protecting personal data collected and
processed as a result of using the SERVICESgoverned by the
aforementioned Terms and Conditions of Use. By accessing and/or
using the SERVICES, you explicitly accept the terms of this Privacy
Policy and, as a consequence, agree to the gathering, retaining,
using and divulging of your personal data, as described herein. You
are hereby advised that the Privacy Policy can be modified by
SPARKYCELLS at any time, and for any APPLICATION. With this in mind,
by continuing to use and/or access the APPLICATION or SERVICES after
the last-modified date of any changes, you will be deemed to have
accepted these changes as modified. You are therefore invited to
regularly consult the Privacy Policy to ensure you are up-to-date
with any potential changes.
Our SERVICES may use our BUSINESS PARTNERS' technology. In such
case, their own privacy policy are applicable to such SERVICES.
- BUSINESS PARTNER: Appodeal (privacy policy)
2. DATA COLLECTION
2.1 Data collected by SPARKYCELLS via the PLATFORMS
The data collected and processed are willingly supplied by you to
SPARKYCELLS by agreeing to access and use THE APP or SERVICES
through the PLATFORMS. Such data will include, when available, your
name, profile photo, gender, your network(s), username, the user ID
numbers of your friends and/or people belonging to your network(s)
and other information supplied by you to all users of the PLATFORMS.
If applicable, SPARKYCELLS, through THE APP or SERVICES, is also
likely to collect, still via the PLATFORMS, any additional data you
may agree to supply to it (e.g., your email address, ). As all
personal data are supplied directly to SPARKYCELLS through THE APP
or SERVICES, by the PLATFORMS, it is deemed that you have read and
agreed to the PLATFORMS’ terms and conditions of use and their
privacy policy. SPARKYCELLS shall not be held liable for the way in
which PLATFORMS act in terms of collecting, storing and processing
your personal data. In addition, you are responsible for the privacy
settings of your accounts on the PLATFORMS in such a way that
SPARKYCELLS, or any of THE APP or SERVICES cannot be held liable in
this regard.
2.2 Data collected by SPARKYCELLS directly
Through provision of its SERVICES, SPARKYCELLS may also collect
data from you directly. As such, by using certain features within
the SERVICESwhich require online payment, you agree that your bank
details, your user IDs, your email address and/or your telephone
number may be collected in compliance with current regulations in
force.
SPARKYCELLS DO NOT COLLECT and/or process the following
informations: Race and ethnicity, Political or religious beliefs,
Sexual orientation.
Within the context of using its SERVICES and/or related official
spaces (dedicated official spaces on the PLATFORMS, support website,
etc.), SPARKYCELLS may also invite you to participate in promotional
events (contests, free sweepstakes, etc.), or “closed beta testing”
of their SERVICES. Participation in these promotional events or
closed beta testing implies your full and complete agreement to the
collection, storage and processing of any personal data you supply.
If applicable, and within the context of using THE APP or SERVICES,
the number of points you collect may be retained in order to
determine your rank/level with the particular purpose of defining
player rankings. By using THE APP or SERVICES, you agree, in
particular, that your score, your rank/level, your ID and your photo
be listed in the overall player ranking, which all users of the THE
APP or SERVICES will be able to view. Furthermore, when you contact
SPARKYCELLS (or his provider in charge) directly via its support
service, the latter may collect and store your contact data (in
particular your name, mailing address and email address) and, where
applicable, your user ID number for the PLATFORMS from where you
access and use the THE APP or SERVICES, as well as some information
relating to your use of THE APP or SERVICES that you will provide to
SPARKYCELLS. Finally, SPARKYCELLS may need to collect aggregate data
in order to be able to provide an optimized level of SERVICES. This
may include data such as your IP address, browser type, browser
language, number of clicks, pages viewed and also, more generally,
browsing and connection data.
2.3 Data collected by our BUSINESS PARTNERS
Through provision of its SERVICES, our BUSINESS PARTNERS may also
collect data from you, in respect of their own privacy policy.
3. PURPOSES OF COLLECTING AND PROCESSING YOUR DATA
3.1 Data collected and processed by the PLATFORMS
The PLATFORMS collects, stores and processes your personal data
with the aim of enabling you to access and use the SERVICES
effectively.
3.2 Data collected and processed by SPARKYCELLS
SPARKYCELLS, via his SERVICES can also directly collect your data
from you, and then store and process it with the aim of enabling you
to access and use its SERVICES effectively, or with the aim of
improving their SERVICES by analyzing their users behaviour (note
that NO data can be used to directly identify any of our user).
3.3 Collecting and processing your data
Data collected from the PLATFORMS and/or directly from you enable
in particular the better administration and improvement of the
SERVICES, communication between users of the SERVICES, the supply of
technical support and efficient responses to user requests, proper
application of the Terms and Conditions of Use, which govern
SPARKYCELLS’s SERVICES, communication about new and current SERVICES
along with promotional offers, the analysis of user traffic trends
and the collection of statistical data or even the targeting of
advertising content that may appear on our SERVICES. When you
receive relational or promotional communications on behalf of
SPARKYCELLS, you will have the opportunity to put and end to them by
following the unsubscribe instructions contained in the
communication itself.
3.4 Data collected and processed by our BUSINESS PARTNERS
Through provision of its SERVICES, our BUSINESS PARTNERS may also
collect and process data from you, in respect of their own privacy
policy.
4. RECIPIENTS OF YOUR DATA
Your data will not be provided to third parties, except in the
following cases:
- When SPARKYCELLS must share your data with commercial partners,
suppliers, service providers and in particular, technical service
providers, resellers and buyers, with the aim of providing our
SERVICES, resolving functionality problems of our SERVICES,
communicating with users of our SERVICES or with a view to providing
advertising and promotional information related to our SERVICES;
- In particular, SPARKYCELLS supplies your data to third parties
that provide services on their behalf, including payment processing,
data analysis, email campaign processing, the hosting of SERVICES
and the processing of certain marketing activities for its SERVICES;
- SPARKYCELLS may communicate your data in applying a law,
regulation or in accordance with a decision from an appropriate
regulating or legal authority or, if it proves necessary, with the
aim of safeguarding its rights and interests;
- SPARKYCELLS will be authorized to transfer your data in
compliance with article 10 of the present regulations in the event
of a change of control of SPARKYCELLS or a cessation of all or part
of its activities.
- When you have given prior agreement to the sharing and/or
divulging of your data, including by features offered on the
PLATFORMS;
We would like to draw your attention in particular to the fact that
by using certain SPARKYCELLS SERVICES via the PLATFORMS, other users
of these SERVICES will be able to view your user profile for these
PLATFORMS. This profile may enable other users to obtain information
associated with this profile made public by you. SPARKYCELLS cannot
be held liable in this regard. The settings for information
associated with your profile are your responsibility. SPARKYCELLS
does not share your personal data with third-party advertisers for
marketing purposes unless you have provided prior consent for it.
Nevertheless, it should be noted that advertisers may obtain
personal data which relates to you from your user profile on the
PLATFORMS or from other public sources. In the same way, SPARKYCELLS
shall not be held responsible in this regard. On the other hand,
SPARKYCELLS may use and share certain non-personal technical or
aggregate data relating to the browsing of SERVICES users with
certain third parties. Please refer to article 7 for a few examples
of browsing data. SPARKYCELLS may allow advertisers to collect this
type of technical or aggregate data using certain technology such as
cookies and to do so in order to be able to offer targeted
advertising within the more general context of personalizing your
user experience. The gathering, processing and divulging of such
anonymous data shall not be subject to the restrictions cited in the
current privacy policy.
5. SECURITY OF YOUR DATA
SPARKYCELLS does its absolute best to protect your personal data
and therefore to limit the risk of any loss, deterioration or
incorrect use of it. All your sensitive information, such as a
credit card number or password while using our SERVICES, are managed
by the PLATFORMS themselves.
Our BUSINESS PARTNERS do their best to protect your personal data.
6. SAFEGUARDING OF YOUR DATA
Your personal data is stored with the host identified in the Legal
Section and are held for the period of time necessary for carrying
out the aforementioned purposes. Beyond this period of time, they
will be kept exclusively for statistical purposes and will not be
used in any other way whatsoever.
7. COOKIES
Within the context of facilitating your access and use of the
SERVICES, of personalizing this access and use and also of enabling
us to manage the advertising which may be viewed from our SERVICES,
you are advised that SPARKYCELLS is likely to apply an automatic
tracking procedure (cookie). A cookie does not enable you to be
identified. On the other hand, it records information relating to
your computer’s browsing of sites from where you have accessed the
SERVICES and other associated areas (pages you have viewed, the date
and time of viewing, etc.) that we will be able to read during your
subsequent visits. However, you can opt to turn off “Cookies” by
configuring your browser according to the instructions indicated on
the Wikihow website
here:http://www.wikihow.com/Clear-Your-Browser’s-Cookies. Please
note that configuring your browser in this way may change the
quality of the SERVICES.
8. THIRD-PARTY PRIVACY POLICY
The SERVICES may contain links to third-party websites. Likewise,
certain SERVICES content (advertising related or otherwise) may be
hosted with third parties. Finally, within the context of certain
SERVICES features requiring online payment, you may be asked to use
secure payment tools provided by third-party companies. SPARKYCELLS
cannot be held liable for practices relating to the collection,
storage and processing of personal data by these third parties
and/or the content of their websites. You warrant SPARKYCELLS
against any complaint, action and procedure initiated in this
regard. If you have any questions about the use of your personal
data by these third parties, you should refer to their applicable
privacy policies and contact the third-party companies directly.
9. INTERNATIONAL TRANSFER OF DATA
For the purposes of the SERVICES’ functioning, personal data
collected by SPARKYCELLS are hosted in the USA. SPARKYCELLS and its
host respect the SafeHarbor framework as cited by the Department of
Trade concerning the collection, use and retention of online user
data from the European Union. SPARKYCELLS takes all reasonable
measures to ensure that your data are processed in complete security
and in compliance with this Privacy Policy. By submitting your data
to SPARKYCELLS and, more generally, by accessing and using the
SERVICES, you agree to the transfer, storage and/or processing of
your data in the USA.
10. CESSATION / TRANSFER
SPARKYCELLS reserves the right to transfer your personal data in
the event of a change of control or the cessation of all or part of
its activities, in particular through acquisition or merger with
another company. In such a case, SPARKYCELLS will use all means to
warn users of any such transfer and if applicable, any change
affecting the Privacy Policy.
11. PRIVACY POLICY CONCERNING CHILDREN UNDER 13
The SERVICES offered by SPARKYCELLS are NOT intended for children
under 13. Anyone under 13 shall NOT use the SERVICES. With this in
mind, SPARKYCELLS does not willingly collect personal data from
children under 13. All the same, if the collection of such data is
brought to the attention of SPARKYCELLS, we will take all useful
measures possible to delete the corresponding data.
12. RIGHT OF ACCESS, MODIFICATION AND DELETION OF YOUR PERSONAL
DATA
In compliance with legal provisions, you have a general right to
access, edit and delete your personal data which have been collected
pursuant to your access to and/or use of the SERVICES. Regarding
data collected via the PLATFORMS in particular, you can access and
edit such data directly from the personal area available to you on
these PLATFORMS. If you have no personal area, you should refer to
the PLATFORMS’ access and editing policy.
5. IF YOU'D LIKE TO ASK US ANY QUESTION
If you have any questions about SPARKYCELLS’ SERVICES or Privacy
Policy, feel free to contact us via email at:
legal@sparkycells.fr