1. AIM OF THE PRIVACY POLICY
The Privacy Policy represents an ongoing commitment by Adapt and its affiliated companies (parent company, subsidiaries, etc.) (hereinafter referred to as Adapt) to ensuring the protection of the personal data and privacy of users of the services described herein. This is done in accordance with applicable regulations, including Law 78-17 of January 6, 1978, relating to information technology, files and freedom, the European Union’s General Data Protection Regulation (GDPR) (EU) 2016/679, and the California Consumer Privacy Act (CCPA), as well as other relevant US federal laws. The
current Privacy Policy is an integral part of the Terms and Conditions
of Use governing the games and software applications provided by
Adapt, 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 Adapt in terms of protecting personal
data collected and processed as a result of using the Services
governed 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 Adapt at any time. With this in mind, by continuing to use and/or
access the 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.
2. DATA COLLECTION
2.1 Data collected by Adapt via the Platforms
The data collected and processed are willingly supplied by you to
Adapt through the Platforms by agreeing to access and use the Services
from these Platforms. At a minimum, such data will include your name,
profile photo, sex, 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, Adapt 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 Adapt by the
Platforms, it is deemed that you have read and agreed to the
Platforms’ terms and conditions of use and their privacy policy. Adapt
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 Adapt cannot be held liable in this
regard.
2.2 Data collected by Adapt directly
Through provision of its Services, Adapt may also collect data from
you directly. As such, by using certain features within the Services
which require online payment, you agree that your bank details, email
address and/or your telephone number may be collected in compliance
with current regulations in force. Within the context of using its
Services and/or related official spaces (dedicated official spaces on
the Platforms, support website, etc.), Adapt may also invite you to
participate in promotional events (contests, free sweepstakes, etc.).
Participation in these promotional events 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 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 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
Services will be able to view. Furthermore, when you contact Adapt
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 Services, as well as some
information relating to your use of the Services that you will provide
to Adapt. Finally, Adapt 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.
3. PURPOSES OF COLLECTING AND PROCESSING YOUR DATA
Adapt collects, stores and processes your personal data with the aim
of enabling you to access and use its Services effectively. 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 Adapt 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 promotional communications on
behalf of Adapt, you will have the opportunity to put and end to them
by following the unsubscribe instructions contained in the
communication itself.
4. RECIPIENTS OF YOUR DATA
Your data will not be provided to third parties, except in the
following cases:
-
when Adapt must share your data with commercial partners,
suppliers, service providers and in particular, technical service
providers, resellers and buyers, with the aim of providing
Services, resolving functionality problems of Services,
communicating with users of the Services or with a view to
providing advertising and promotional information related to
Services;
-
in particular, Adapt 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;
-
Adapt 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;
-
Adapt 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 Adapt 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 Adapt 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. Adapt cannot be
held liable in this regard. The settings for information associated
with your profile are your responsibility. Adapt 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, Adapt shall not be held responsible
in this regard. On the other hand, Adapt 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. Adapt 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
Adapt does its absolute best to protect your personal data and
therefore to limit the risk of any loss, deterioration or incorrect
use of it. As such, when you enter sensitive information such as a
credit card number or password while using our Services, we encode
said information using the “SSL” cryptographic protocol (for more
information about SSL, go to
http://en.wikipedia.org/wiki/Secure_Sockets_Layer). In spite of the
security measures undertaken, Adapt shall not guarantee the
transporting and integrity of data transmitted to third parties
through the Services (for example, when buying Physical and Virtual
Products) and cannot be held liable in this regard. You accept in
particular the limits and risks inherent to using the Internet and you
promise as of now to take all preventive measures available to you to
safeguard the privacy of your personal data (including any potential
account passwords required to use the Services).
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 Adapt 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. Adapt 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 Adapt 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. TRANSFER OF DATA INTERNATIONALLY
For the purposes of the Services’ functioning, personal data collected
by Adapt are hosted in the USA. Adapt 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. Adapt 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 Adapt 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
Adapt 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, Adapt 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 Adapt are not intended for children under 13. Anyone under 13 should not use the Services. In accordance with the Children’s Online Privacy Protection Act (COPPA), Adapt does not knowingly collect personal data from children under the age of 13 without verifiable parental consent. If it is brought to Adapt’s attention that personal data from a child under 13 has been collected without such consent, Adapt will take all reasonable measures to promptly delete the corresponding data from its records.
12. RIGHT OF ACCESS, MODIFICATION AND DELETION OF YOUR PERSONAL DATA
In compliance with legal provisions, including the General Data Protection Regulation (GDPR) for EU residents and the California Consumer Privacy Act (CCPA) for California residents, you have the right to access, edit, delete, and request the portability of your personal data that has been collected in connection with your access to and/or use of the Services. For data collected via the Platforms, you can access and edit such data directly through the personal area available to you on these Platforms. If no personal area is available, you should refer to the Platforms’ access and editing policy. Additionally, you have the right to request that Adapt disclose the categories of data collected about you and the purposes for which your data is used. To exercise these rights, please contact us using the details provided in this Privacy Policy.
13. ANY QUESTIONS?
If you have any questions about Adapt’ Services or Privacy Policy,
feel free to contact us via email at contact.app.adapt@gmail.com