Personal data protection policy relating to tools and technologies integrated into games
PulluP Entertainment– Entry into force of the latest update: 22 October 2024
PulluP Entertainment (hereinafter ‘we’ or ‘us’ or ‘PulluP Entertainment’) takes great care to protect your personal data (hereinafter ‘the Data’ or ‘your Data’) and to respect your privacy. This Privacy Policy (the ‘Policy’) provides transparent information about the protection of your Data collected and processed by PulluP Entertainment as a Data Processor through the Publishers' games.
In accordance with its legal obligations, and in order to ensure the proper application of these rules, PulluP Entertainment has appointed a Data Protection Officer (DPO) who you can contact:
- by email at the following email address: personaldata@pullupent.com ; or
- by post: PulluP Entertainment, Parc du Pont de Flandre, Bâtiment 28 “Le Beauvaisis”, 11 rue de Cambrai, 75019 PARIS.
SUMMARY
- Definition
- Description of Data Processing
- Recipients of the Data collected
- Transfer of Data outside the EEA
- How to exercise your rights
- Security of Data
- Minors
- Modification and updating of the Policy
1. DÉFINITIONS
Data Controller or Publisher: refers to any company belonging to the PulluP Entertainment group which publishes and distributes video games developed by development studios within or outside the group, and which, alone or jointly with others, determines the purposes and means of Data processing.
Data Processor or PulluP Entertainment: refers to the company PULLUP ENTERTAINMENT, a limited company registered under number 399 856 277 with the PARIS Trade and Companies Register, whose registered office is located at Parc du Pont de Flandre, Bâtiment 28 ‘Le Beauvaisis’, 11 rue de Cambrai, 75019 PARIS (France), which acts as a data processor in the context of processing relating to the tools and technologies integrated into the games, and processes Data on behalf of the Data Controller.
Personal Data or Data: means information, in any form whatsoever, directly or indirectly relating to an identified or identifiable natural person.
Publisher: refers to any company belonging to the PulluP Entertainment group that publishes and distributes video games developed by internal or external development studios.
Player: refers to any person accessing games published by the Publisher.
2. DESCRIPTION OF DATA PROCESSING
PulluP Entertainment, as the Publisher's Data Processor, collects your Data directly when you use the Publisher's video games, when:
- You access certain games offering online features (multiplayer games, ranking systems, cross-platform saves);
- You consent to the analysis of your game data in the context of your use of video games on which telemetry is activated.
| PROCESSING | DATA SUBJECTS | DATA CATEGORIES | PURPOSE(S) OF THE PROCESSING | LEGAL BASIS OF THE PROCESSING | RETENTION PERIODS |
|---|---|---|---|---|---|
| Tools and technologies integrated into games (including telemetry) | Players |
Game data |
Improve the game and gaming experience |
Performance of the End User Licence Agreement Consent* | For a maximum period of 2 years from their collection, unless the data subjects object or withdraw their consent and before the expiry of this retention period. At the end of this period, the data is anonymised or deleted. |
| Management of requests to exercise rights | Anyone sending us a request |
|
Manage and monitor requests to exercise rights received and ensure the effective processing thereof | Legal obligation: Respond to requests made by data subjects, pursuant to the GDPR and the Data Protection Act |
Your Data will be kept for the period necessary to process your request, increased by the legal limitation periods: 6 years for the right of opposition, 5 years for the other rights. |
*For all processing based on your consent, you are informed that you may withdraw your consent at any time, free of charge, by contacting us and following the procedure described in section 5 below.
The Data collected is kept only for as long as is necessary to achieve the purpose for which it was collected (known as ‘active’ use) and in compliance with applicable laws.
Where PulluP Entertainment is justified in keeping your Data for longer periods, this Data is kept in an intermediate archive, i.e. separate from the active database and with restricted access.
Once these periods have expired, we will delete or anonymise your Data.
3. RECIPIENTS OF THE DATA COLLECTED
Some of the Data we collect may be communicated to and/or shared with: development studios, our technical and IT service providers or our suppliers. Where applicable, the communication and/or sharing is carried out for technical and operational purposes, to enable us to offer you high-performance games.
In all cases, we put in place the necessary contractual and organisational measures to ensure that the processing of your Data by these third party service providers is strictly limited to the purposes defined in this Policy and to guarantee the confidentiality and security of your Data.
4. TRANSFER OF DATA OUTSIDE THE EEA
Upon documented instructions from the Publisher, PulluP Entertainment may transfer some of your Data outside the European Economic Area (EEA), for technical and operational purposes, to enable us to provide you with the requested services. These transfers are carried out in accordance with the applicable data protection regulations and with the transfer control solutions recognised by the RGPD.
In particular, where the transfer of your Data cannot be carried out on the basis of an adequacy decision by the European Commission recognising an adequate level of protection, we put in place other transfer mechanisms and appropriate safeguards to ensure the protection of your Data, including data transfer agreements comprising the standard contractual clauses approved by the European Commission in the version in force at the time of the relevant transfer, or other arrangements recognised by these regulations, including the new EU-US Data Protection Framework.
For more information on guarantees relating to the transfer of Data, you are invited to contact us at the following address: personaldata@pullupent.com.
5. HOW TO EXERCICE YOUR RIGHTS
You have all of the following rights to the Data about you that we collect and process:
- Right to access your Data: you have the right to obtain (i) confirmation that your Data are or are not processed; when they have been processed, (ii) access to these Data and (iii) a copy of the Data processed by PulluP Entertainment, in an understandable format;
- Right to request the modification, updating or rectification of your Data when you consider it inaccurate, incorrect or incomplete;
- Right to request the deletion of your Data for the reasons provided for by the applicable regulations;
- Right to limit the processing of Data concerning you for the reasons provided for by the applicable regulations;
-
Right to object to the processing of your Data if we use your Data:
- For our legitimate interests;
- For statistical purposes; or
- Right to withdraw your consent at any time when the processing is based on your consent (it being recalled that this withdrawal will not affect the lawfulness of the processing, based on consent, carried out before its withdrawal);
- Where appropriate, the right not to be the subject of a decision based exclusively on automated processing, including profiling, producing legal effects concerning the data subject or affecting the latter significantly in a similar way. Right to the portability of your Data this right applies to the Data that you have transmitted to us when the processing is automated and based on your consent or carried out on the basis of the performance of a contract. You have the right to ask us, if technically feasible, to transfer your Data to a third party or to provide them directly to you in an accessible and machine-readable manner;
- Right to transmit instructions regarding the storage and communication of your Data after your death;
To exercise your rights, you can send your request by specifying the right(s) concerned and the reasons for your request, if applicable:
- by email at the following email address: personaldata@pullupent.com ; or
- by post: PulluP Entertainment, Parc du Pont de Flandre, Bâtiment 28 “Le Beauvaisis”, 11 rue de Cambrai, 75019 PARIS.
We will acknowledge receipt of your request as soon as possible and, if it is admissible, we will provide you with the requested information or implement the rights invoked within one month.
If, given the complexity of the request or the number of requests received, the aforementioned period of one month cannot be respected, we will inform you before the expiry of said period of the postponement of our decision, but not beyond a further two-month period.
In the event of manifestly abusive requests (in particular due to their number, repetitive or systematic nature), PulluP Entertainment will be entitled not to respond to them. If applicable, we will inform you of the reasons for our refusal.
Requests to exercise rights are processed by the authorised teams of PulluP Entertainment as Data Processor, acting on behalf of and on the documented instructions of the Publisher as Data Controller.
6. SECURITY OF DATA
We implement all appropriate technical and organisational measures to guarantee the security, confidentiality and integrity of your Data and to protect your Data against accidental or unlawful destruction, accidental loss, damage, modification, unauthorised disclosure or access, as well as against any other form of unlawful processing.
By way of example, and without this list being exhaustive, we maintain:
- an authentication system to protect access to your online accounts;
- hashing procedures for some of your Data;
- limited access (clearance policy) to only those PulluP Entertainment employees and/or sub-contractors who have a need to know by virtue of their duties, when required to provide our services to you and subject to compliance with strict confidentiality obligations; etc.
We regularly carry out security checks and may temporarily suspend our services if a security breach is suspected or detected. If you have any concerns about the security of your Data, you can contact us at the following address: personaldata@pullupent.com.
7. MINORS
PulluP Entertainment does not intentionally collect Data from minors under the age of 18. If we become aware that we have collected Data relating to a minor within the meaning of the applicable data protection regulations, we will delete any Data relating to that minor without delay.
8. MODIFICATION AND UPDATING OF THE POLICY
We periodically review this Policy to ensure compliance and to keep it up to date with applicable data protection regulations.
Before using the game, we invite you to refer to the latest version of the Policy. You can check whether there have been any changes since you last consulted it by consulting the date at the top of the page.