Privacy policy


DISCLAIMER: THE TRANSLATIONS OF THE TERMS AND CONDITIONS AND PRIVACY POLICY ARE AVAILABLE FOR INFORMATION PURPOSES ONLY. 

PLEASE NOTE THAT IN CASE OF LITIGATION OR DISAGREEMENT, ONLY THE FRENCH VERSIONS ARE LEGALLY VALID. 

THE FRENCH VERSIONS OF THE TERMS AND CONDITIONS, AND THE PRIVACY POLICY TAKE PRECEDENCE OVER THIS TRANSLATION IN ENGLISH IN CASE OF LITIGATION OR DISAGREEMENT.



 

1.    Purpose of this Privacy Policy


a.    Definitions


The EIRL (“Entreprise Individuelle à Responsabilité Limitée” in French) PANETTA designs websites as well as our software such as mobile applications. These are intended to be published by us on legal download platforms.


In this document, the terms "this policy" and "this document" refer to the EIRL PANETTA Privacy Policy (“Politique de Confidentialité” in French).


In this policy, the terms "we", "our", and "ours" refer to EIRL PANETTA.


In this policy, the terms "you", "your", and "yours" refer to the user.


b.    Nature of this document


This privacy policy applies when you download, use or access any of our software, applications, website, or service. The purpose of this privacy policy is to inform you of the use and processing of your personal data by EIRL PANETTA. We invite you to read it carefully.

This document is available directly via the platforms from which our software or mobile applications were obtained, as well as on the following website:

https://eirlpanetta.com/


c.    Acceptance of the Privacy Policy


The installation of one of our software or mobile applications, the use of one of our software, mobile applications, websites, or access to one of our services imply the unreserved acceptance of this policy as well as the terms and conditions (“Conditions générales d’utilisation et de vente” in French).

EIRL PANETTA reserves the right to modify this Privacy Policy unilaterally and at any time. In the event of disagreement with these new provisions, the user may stop using the software or the mobile application.


This contract is concluded for EIRL PANETTA at its head office, for the user at his home address, on the date of downloading the software or the mobile application and for the duration of the license granted by EIRL PANETTA to the user.



d.    Conflict of standards


In the case of a conflict between the terms and conditions and the privacy policy, the terms and conditions take precedence over our privacy policy.



2.    Data controller


EIRL PANETTA is considered responsible for the processing of personal data under the law n°78-17 of January 6, 1978 relating to information technology, files and freedoms and EU Regulation 2016/679 of April 27 2016 on the protection of individuals with regard to the processing of personal data and on the free movement of such data.


The EIRL PANETTA is a structure involving only one person: Mr. Lucien PANETTA. He is therefore the only one to have access to the data collected, and this only to meet the needs of software, mobile applications, or websites.


Nevertheless, state bodies can through legal requests claim access to certain data, and EIRL PANETTA may transmit these data to comply with said requests.



3.    Information collected


EIRL PANETTA processes and collects personal data about you when you use one of our software, mobile applications, website, or service. Data can be recovered in three distinct ways:

• When you provide us with personal data directly.

• When we automatically collect personal data.

• When you make a report or request to our services.


a.    Personal data provided by the user


EIRL PANETTA software or mobile applications do not require registration, user account or member area. Therefore, the user does not have to provide us with direct personal data when using any of our software or mobile application.


b.    Personal data collected automatically


The EIRL PANETTA does not collect or archive any data automatically. However, our software or mobile applications may require certain information to function properly.

Here is a non-exhaustive list of information that can be used when using one of our software or mobile applications:

• Language of your device.

• Apple's Game Center nickname when playing an online game with another user.

• Phone version.

• Application version.

None of the above information is accessible to other users, with the exception of the Nickname Game Center which can be transmitted to your opponent during an online game. In addition, this data is neither collected nor archived by EIRL PANETTA: it is only used when you use one of our software or mobile applications.


The legal bases on which the EIRL PANETTA is based to use this data are the execution of the contract as well as the legitimate interest: the use of this data is necessary for the proper functioning of our software or mobile applications in order to execute our respective contractual obligations.

The purpose of this use is therefore to perform the contract that binds EIRL PANETTA to the user to provide the latter with the information and services requested.



c.    Personal data provided during a report or a request to our services


It is possible to report illegal behavior on our website (https://eirlpanetta.com/) as explained in the conditions of use and sale in Article 11.d “Reporting illegal behavior ”.

When the user makes a request or a report on our website or via e-mail, personal data such as the user's identity, his age as well as the content of said request are collected in order to best respond to this one.

The legal basis on which the EIRL PANETTA is based to collect data during a report or a request is the legal obligation: it is our legal responsibility to remove illegal content from our software or mobile applications as soon as we become aware of it.


4.    Using the Apple Game Center service to access the online service


Certain features of our software or mobile applications are only available through connection to the Apple Game Center service. This is particularly the case when playing online with other users of the same software or mobile application.

In our software or mobile applications, the online service is generally indicated by the “Online” section or button.


We would like to point out to you that we have no access or control over your Apple Game Center service ID or password, and that we are not involved in the login or authentication process.

We simply launch an authentication request when starting the application:

•    If you are automatically logged into Apple's Game Center service on your device, you will automatically be logged into your Game Center account when you use our software or mobile application, and you will be able to access the online service of the software or mobile application.

•    If you are not automatically logged into Apple's Game Center service on your device, you will be prompted to identify yourself. You can, however, choose not to log into Apple's Game Center service, and thus continue to use our software or mobile application without being authenticated. However, please note that you will not have access to the online service of our software or mobile application in the case where you refuse to authenticate with Apple's Game Center service.


Apple's Game Center service is governed by:

•    Apple's Terms and Conditions available at the address below:

https://www.apple.com/ca/fr/legal/internet-services/itunes/gamecenter/cafr/terms.html


•    Apple's Privacy Policy available at the address below:

https://www.apple.com/ca/fr/legal/privacy/


Therefore, any report of abusive, shocking, fraudulent or illegal behavior regarding Apple's Game Center service should be reported directly to Apple. Indeed, we have no control over this particular service.


5.    Promotional and advertising messages


EIRL PANETTA reserves the right to provide advertisers or partners with advertising space on software and mobile applications.

However, EIRL PANETTA is not responsible for, and has no control over, the content of advertising or promotional messages from advertisers or partners.


The advertising networks that allow the advertisements to be placed on the advertising spaces of the software and mobile applications of EIRL PANETTA may collect the following data:

•    The IP address, which can be used to estimate the approximate location of a device. These data are linked to users.

•    The "crash logs" (time-stamped logbooks which allow to know the events which may have occurred on a server, computer, software, or mobile application) which can be used to diagnose problems and improve SDKs (“Software Development Kit”) necessary for the implementation of advertisements on software and mobile applications. Diagnostic information can also be used for advertising or analytical purposes. These data are not linked to users.

•    The ID Device such as the advertising identifier of the device or other device identifiers linked to the software or to the mobile application which can be used for third-party advertising and analytics. These data are linked to users.

•    Advertising data, such as advertisements the user has seen, can be used to fuel analytics and advertising features. These data are linked to users.

•    Other user product interactions, such as app launch taps, and interaction information, such as video views, can be used to improve advertising performance. These data are linked to users.


If the user uses optional product features that involve additional data (such as advanced reporting) or if the user participates in testing of new product features that involve additional data, it is the responsibility of the user to check if those features or tests require additional data disclosures.

6.    Integrated purchases and transactions


This section only concerns software or mobile applications available on mobile application upload platforms.

The payment is managed and processed by the online platform for mobile applications.

We have no control over the currency, payment, fees involved in these transactions, or even the transfer of funds. Only mobile application upload platforms are responsible for payment terms and operations.


In addition, we do not collect or have access to any banking data through our software or mobile applications. When making a purchase, banking data is collected, processed, and managed by online mobile application platforms.


7.    Using backup files


Our software or mobile applications may save files locally on your device (within the software or mobile application folder) such as, for example, ".txt" or ".data" files for technical purposes. This can in particular be the case when saving your game automatically or manually in a game for example. Since these files are stored within the folder, software or mobile application, they are normally deleted if the software or mobile application is uninstalled.


8.    Personal data of children or minors


EIRL PANETTA refuses any collection of data from persons under the age of 15 in accordance with the provisions of the General Data Protection Regulation. If a minor under the age of 15 impersonates an adult, we invite their parents or legal guardians to contact us in order to erase the data that may have been collected.


9.    Retention period of personal data


Personal data is only collected for a period of one year after you have finished processing your request or report.


10.    User rights over the data collected


The user can contact us by email or make a request directly on our website to assert his rights over the data collected. The user must also provide proof of his identity when requesting.

As a reminder, the General Data Protection Regulation (GDPR) indicates all the user's rights over the data collected.

The user rights are as follows:

•    Right of access of the person to his personal data;

•    Right to rectify personal data collected;

•    Right to data portability;

•    Right to object to the collection of personal data;

•    Right to erasure of personal data;

•    Right to limit the processing of personal data.


We invite you to read the General Data Protection Regulations (GDPR) before using any of our software, mobile applications, websites, or services.


EIRL PANETTA undertakes to process user requests concerning the collection, processing, and retention period of their personal data as soon as possible.


11.    Contact


For any questions relating to this privacy policy or for any other request relating to your personal data, you can contact us via our website at the following address https://eirlpanetta.com/ or send us an email (daigla.contact@gmail.com).


12.    Applicable law


These terms and conditions (“Conditions générales d’utilisation et de vente” in French) as well as the privacy policy (“Politique de Confidentialité” in French) are subject to French law, to the exclusion of any conflict of law rules.


The translations of the terms and conditions and privacy policy are available for information purposes only. Please note that in case of litigation or disagreement, only the French versions are legally valid. The French versions of the terms and conditions, and the privacy policy take precedence over this translation in English in case of litigation or disagreement.


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