Disclaimer: This document is an English translation of the original French text for informational and convenience purposes only. In case of any discrepancies, contradictions, or differences in interpretation between this translation and the original French version, the French version shall prevail as the official and legally binding document.
At PlayAbility, protecting your personal data is a priority.
When you use the website https://www.playability.gg ("the Website") and/or the PlayAbility software ("the Software"), and in the context of managing our contractual relationships with our clients, we collect personal data about you.
The purpose of this policy is to inform you about the ways in which we process these data in compliance with Regulation (EU) 2016/679 of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data ("GDPR") and Law No. 78-17 of 6 January 1978 on data processing, files, and freedoms (together, "Applicable Regulations").
Who is the Data Controller?
The data controller is PlayAbility, a simplified joint-stock company registered with the RCS of Bobigny under number 978 633 964, with its registered head office at 95 Avenue du Président Wilson – 93100 MONTREUIL ("We").
What Data Do We Collect?
Personal data is data that can identify an individual directly or through cross-referencing with other data.
We collect personal data in the following categories:
- Identification data (name, first name, email and postal address, telephone number);
- Data related to your gaming mode choice (which part of your body do you wish to use the Software with);
- Data related to your body movements, facial expressions, and voice;
- Professional life data (company name, resume, position/function, LinkedIn URL);
- Data related to your purchases in the Software;
- Connection data (connection logs, encrypted passwords);
- Browsing data (IP address, pages visited, date and time of connection, browser used, operating system, user ID, MAID);
- Economic and financial data (data related to your bank cards);
- Any information you wish to transmit to us in the context of your contact request and in our forms.
Mandatory data is indicated with an asterisk when you provide us with your data.
For What Purposes, On What Legal Bases, and For How Long Do We Keep Your Personal Data?
Providing our services available on our Software through your account
Execution of pre-contractual measures taken at your request and/or execution of the contract you have subscribed to with Us
Data related to your account is kept for the duration of your account.
Your connection logs are kept for 1 year.
Additionally, your data may be archived for evidentiary purposes for a period of 5 years.
Performing operations related to the management of our clients concerning contracts, in-Software purchases, invoices, and ensuring the follow-up of the contractual relationship with our clients
Execution of the contract you have subscribed to with Us
Personal data is kept for the duration of the contractual relationship.
Additionally, your data (except bank details) are archived for evidentiary purposes for a period of 5 years.
Regarding data related to your bank card, they are kept by our payment service provider, STRIPE.
Data related to the visual cryptogram or CVV2 on your bank card are not stored.
Managing your opinions about our services and our Software
Our legitimate interest in collecting your opinions on our services and our Software
2 years from the publication of the opinion
Constituting a file of clients and prospects
Our legitimate interest in developing and promoting our activity
For clients: data is kept for the duration of the contractual relationship.
For prospects: data is kept for a period of 3 years from your last contact.
Complying with our legal obligations regarding the reporting of illegal content on the Software
Complying with our legal and regulatory obligations in the context of our Software
Data related to your identity are kept for 5 years from the end of the validity of the GTC, the closure of your account, or the closure of the report.
Other information provided by the user, especially payment-related information, is kept for one year from the end of the validity of the GTC, the closure of your account, or the closure of the report.
Technical data allowing the identification of the source of the connection or data related to the terminal equipment used are kept for a period of one year from the connection or use of the terminal equipment.
Sending newsletters, solicitations, and promotional emails
For clients: our legitimate interest in retaining and informing our clients of our latest newsFor prospects: your consent
Data is kept for 3 years from your last contact with Us or until the withdrawal of your consent.
Responding to your information requests
Our legitimate interest in responding to your requests
Data is kept for a period of 3 years from your last contact.
Complying with the legal obligations applicable to our activity
Complying with our legal and regulatory obligations
Invoices are archived for a period of 10 years.
Data related to your transactions (except banking data) are kept for 5 years.
Processing applications and managing interviews (pre-selection of candidates, contact to assess the candidate's ability to hold the position, finalization of the recruitment process)
Execution of pre-contractual measures
Your data are kept in active base for the entire duration of the recruitment process until the hiring decision.
In case of refusal of your application, your data can be kept for 3 months after the end of recruitment to provide explanations on the reasons for rejecting your application.
Your data can be kept in intermediate archiving for evidentiary purposes for 5 years from the date of the hiring decision.
Organizing contests and promotional operations
Our legitimate interest in retaining our clientele and offering them gifts
Data is kept for the entire duration of the games or promotional operations and may be archived for 5 years for evidentiary purposes.
Developing statistics (of navigation, audience of the Website and Software) and improving the functionalities of the Website and Software through the use of audience measurement cookies
Data is kept for 25 months.
Managing requests for exercising rights
Our legitimate interest in responding to your requests and keeping track of them
If we ask you for proof of identity: we keep it only for the time necessary for identity verification. Once verification is done, the proof is deleted.Information allowing the management of your requests for exercising rights under the GDPR will be kept for 3 years from the request.
Who Are the Recipients of Your Data?
The following will have access to your personal data:(i) Our company's staff;(ii) Our subcontractors: hosting provider, newsletter sending provider, audience measurement and analysis provider, email messaging provider, secure payment provider, invoicing tool, cookie management tool, CRM tool, customer service and chatbot provider, database provider, form generator, task automation tool;(iii) If applicable: public and private organizations exclusively to meet our legal obligations.
Is Your Data Likely to Be Transferred Outside the European Union?
As part of the tools we use (see the section on recipients concerning our subcontractors), your data may be subject to transfers outside the European Union. The transfer of your data in this context is secured using the following tools:
- Either the data is transferred to a country that has been the subject of an adequacy decision by the European Commission in accordance with Article 45 of the GDPR: in this case, this country ensures a level of protection deemed sufficient and adequate to the provisions of the GDPR;
- Or the data is transferred to a country whose level of data protection has not been recognized as adequate to the GDPR: in this case, these transfers are based on appropriate guarantees indicated in Article 46 of the GDPR adapted to each provider, including but not limited to the conclusion of standard contractual clauses approved by the European Commission, the application of binding corporate rules, or under an approved certification mechanism.
- Or the data is transferred on the basis of one of the appropriate guarantees described in Chapter V of the GDPR.
What Are Your Rights Over Your Data?
You have the following rights regarding your personal data:
- Right to information
- Right of access
- Right to rectification
- Right to restriction
- Right to erasure
- Right to file a complaint with a competent supervisory authority
- Right to define directives concerning the storage, erasure, and communication of your personal data after your death
- Right to withdraw your consent at any time
- Right to Data Portability
- Right to Object
You can exercise these rights by writing to us at the contact details below. On this occasion, we may ask you to provide additional information or documents to verify your identity.
Which Cookies Do We Use?
Contact Point to Exercise Your Rights
Contact Email: email@example.com
Contact Address:Attention: PlayAbility95 Avenue du Président Wilson – 93100 MONTREUILFrance
Effective Date: January 25, 2024