PERSONAL DATA PROTECTION POLICY

Last update: April 2021

INFORMATION ABOUT YOUR PERSONAL DATA

 

¥  As processing manager, Playrion processes the personal data you provided for the sole purpose of supplying and managing the App and its different services;

¥  Only Playrion and any of its sub-contractors have access to your personal data. Other players may also have access to some of your personal data in the context of messaging, chat, and the ranking on the App;

¥  With some exceptions, your personal data is kept throughout the period of active use of your account on the App and then archived until the end of the statutory limitation periods;

¥  You have rights regarding your personal data. For any question or to exercise your rights, you can contact Playrion direct by sending an email to [email protected]. For further information regarding the use of your personal data by Playrion, please consult this personal data protection policy.

__________

The Airlines Manager app is a virtual airline management and administration game (hereinafter “the App”). In the frame of using the App and its different services, you are required to communicate personal data to Playrion (hereinafter “Playrion”). This data is protected by law. That is why, as processing manager, Playrion has set up measures to protect your personal data. Please read this policy that explains how your personal data is used by Playrion. If necessary, you can ask any questions you may have by sending an email to [email protected].

1- Which data may be subject to processing by Playrion?

All the data you enter in the App or which you generate in the frame of its use, limited to that which is strictly necessary for the management and provision of the App and its different services:

¥  Identification data (email, Facebook ID, surname, first name, and profile photo associated with your Facebook profile, etc.);

¥  Data relating to your player account on the App (player’s name, unique ID on the App, password, your company's profile, ranking, sponsorship code, etc.);

¥  Bank details;

¥  Contributions (participation on the App’s messaging service or chat, bug reports, reports relating to another player, sharing of content on your social media, etc.). Some data is collected automatically by the App:

¥  Data relating to your location, subject to your consent;

¥  Connection and usage data (your terminal’s make, your terminal’s operating system, your terminal’s unique ID, IP address, date and time of connection, advertising ID, the list of apps installed on your terminal, usage statistics, your browsing history, app error reports, etc.). This data is necessary for the App’s good technical functioning as well as for measuring use of the App. Some data is mandatory, other data is optional for accessing the App’s different services. The mandatory or optional nature of the personal data to be supplied is indicated during collection. If you refuse to provide the mandatory information requested, Playrion will not be able to process certain requests or supply certain services.

2- Why does Playrion use your personal data?

Playrion processes your personal data solely for the following reasons:

¥  The creation and management of your player account on the App. This data is necessary for the performance of the contract (General Terms and Conditions of Use);

¥  The provision of the App and its different services (mini-games, messaging service, chat, ranking, etc.). This data is necessary for the performance of the contract (General Terms and Conditions of Use);

¥  The processing of your virtual money purchase requests (AM Coins, TravelCards and Packs). This data is necessary for the performance of the contract (General Terms and Conditions of Use);

¥  The processing of your specific requests (reporting a bug, reporting another player, information request, etc.). This data is necessary for Playrion to ensure the correct use of the App and, if necessary, reply to you (legitimate interest of Playrion);

¥  The performance of sales operations by sending you newsletters, canvassing messages or promotional content that may be of interest to you and allocating you a sponsorship code. This data is necessary for Playrion to expand its sales activity (legitimate interest of Playrion);

¥  Improvement of the App and your player experience. This data is necessary for Playrion to improve the App and its different services, as well as in order to personalize your player experience (legitimate interest of Playrion);

¥  The display of adverts, the measurement of their effectiveness and the adaptation of their content according to your use and your profile, subject to having firstly obtained your consent;

¥  Comply with legal or regulatory obligations imposed on Playrion.

3- Who can access your personal data?

 

¥  Playrion and its authorized staff;

¥  Other players can access some of your personal data (player’s name, unique ID on the App, your airline’s name, ranking, your airline’s profile) via the “Ranking” section of the App. Furthermore, if you decide to exchange with other players via the App's messaging service or chat, they will be able to access your player’s name, your unique ID on the App, your airline’s name, as well as any personal data communicated in your messages;

¥  Playrion’s suppliers and sub-contractors (such as the App’s facilities management supplier, host, etc.) solely for technical or logistical reasons;

¥  If you consent, Playrion’s partners for advertising purposes;

¥  Administrative or legal authorities on their request in the event of a proven infringement of the legal or regulatory provisions;

¥  Third parties, if necessary, in a summarized or anonymous format, in particular in the frame of a sale, merger or restructuring of the company and only for the needs of the operation concerned and in accordance with the obligation of confidentiality. Your personal data can be transferred to a country located outside the European Union provided that, it being specified that in the event of the recipient country being unable to ensure a level of data protection equivalent to that of the European Union, Playrion undertakes to take all the necessary measures, either on the basis of an adequacy decision, or in the absence of such a decision, on the basis of appropriate guarantees, such as standard contractual clauses, the communication of which may be obtained by sending an email to [email protected].

4- How long is your personal data kept?

In general, your personal data will only be kept for the period required for the purposes for which this data has been collected or in order to conform to legal or regulatory requirements. With some exceptions, Playrion keeps your personal data until your account is deleted or in the case of it being inactive for three (3) years and beyond, for three (3) additional years for data processed for canvassing purposes, and ten (10) years for data kept for accounting purposes. After this period, your personal data is archived for the statutory period of limitation, then destroyed.

5- What are your rights relating to your personal data?

In the frame of the use of the App, you have rights relating to your personal data:

¥  You can request access to the personal data that Playrion has about you and obtain a copy of it, including in electronic format;

¥  You can request the correction, updating, deletion of your personal data and the limitation of its processing;

¥  You can request that use of your personal data is stopped, especially for commercial canvassing purposes;

¥  You can withdraw your consent when it has been obtained without this withdrawal affecting the legality of prior processing;

¥  You can communicate your “last wishes” relating to your personal data in the event of your death (for example, its deletion or its transmission to any person of your choice). In some cases, you must explain to Playrion why you are exercising one of these rights and, if necessary, justify your identity. For any question and to exercise your rights, you can contact Playrion direct by sending an email to [email protected]. If you are not satisfied with the answers provided, you can file a complaint with the French Data Protection Authority (CNIL: Commission Nationale de l'Informatique et des Libertés) via its website or by mail: 3, place de Fontenoy - TSA 80715 - 75334 PARIS CEDEX 07. This right can be exercised at any time free of charge, with the exception of the cost of postage if applicable, and any support or representation costs if you decide to seek help from a third-party for this procedure.