DATA PROTECTION POLICY PLUS GAMES

This Data Protection Policy describes the collection and further processing of personal data by Plus Games, 5 rue des Alliés, 38100 Grenoble, France also called "SARL Plus Games").

Plus Games attaches great importance to the protection of personal data and collects, processes and uses and personal data solely for providing and improving its products and services and in accordance with the principles described below and in compliance with the applicable data protection provisions. Personal data is all information relating to an identified or identifiable natural person, which includes, for example, your name as well as your postal and e-mail addresses.

In the event that the activities covered by this notice are governed by other data protection policies, are evident from the circumstances, or are governed by applicable laws outside of the European Union and the European Economic Area, then such applicable law and resulting policies shall control. The term personal data shall include all information relating to an identified or identifiable person.

This Data Protection Policy describes the general processing of personal data by Plus Games in Section A. Section B describes specific provisions for specific applications (e.g. payment, newsletter and personalized advertisement).

If you choose to use After The End, then you agree to the collection and use of information in relation to this policy. If the user provides personal data of other persons (i.e. invitation of a friend) to Plus Games, the user should only provide such personal data if he is entitled to do so and in compliance with the applicable data protection regulations and only if the affected person agrees to said disclosure according to this data protection policy.

The terms used in this Privacy Policy have the same meanings as in our Terms and Conditions, which is accessible at After The End unless otherwise defined in this Privacy Policy.
A) GENERAL PROVISIONS

1. DATA CONTROLLER, DATA PROTECTION OFFICER

The Data Controller in accordance with the the EU General Data Protection Regulation (GDPR) of any user touchpoint of After The End shall be Plus Games SARL, 35 rue des Alliés, 38100 Grenoble, France.

Plus Games has not appointed a data protection officer according to article 37 GDPR.
2. PROCESSING OF PERSONAL DATA

Plus Games collects and processes personal data of

users and registered users of a After The End (i.e. users, account holders etc.);
  • individuals purchasing and receiving/benefitting products and services of Plus Games;
  • potential users of the Plus Games products and services;
  • participants in research campaigns and opinion surveys conducted by Plus Games (such as beta versions of Smart Device Applications etc.);
(together "Users").

The personal data of Users is generally collected directly by Plus Games while using After The End as well as through direct communication such as email, telephone or in any other way possible. Personal data can also be collected indirectly through third-party processors (e.g., Plus Games's Partners (as defined further below, including but not limited to dealers, suppliers and other business partners).

In particular, the following categories of personal data are processed by Plus Games:

  • Personal data including but not limited to nickname, email address, country, IP, GAID and other identificators;
  • Data pertaining to orders and purchases including but not limited to billing address, products and services ordered and purchased, information and queries and complaints relating to products and services, User care, rescissions and disputes;
  • Geo-Tracking Data including but not limited to routes, locations, duration of stay:
  • Data in connection with marketing and communication, including but not limited to information relating to communication channels, opt-ins and opt-outs, invitations to and participations at events and special activities, communication preferences, correspondence and communication with Plus Games (including records of the communication); personal preferences and interests and User segmentation information.
  • Data in connection with communication including but not limited to preferred means of communication, correspondence and communication with Plus Games (including records of the communication);
(together "User Data")

In addition, Plus Games collects:

  • Personal Data of employees of partners dealers, retailers, suppliers and further business partners of Plus games ("Partner Data") including but not limited to contact details, function, previous contacts, marketing activities (e.g. newsletters etc.), business transactions, requests, offers, tenders, conditions and contracts, professional or other interests of the individuals.
In the course of business, Users will be required to provide User Data necessary regarding the products and services or if required by law. Without this data, Plus Games will not be able to render its products and services to the User. This provision shall analogously apply to Partner Data.

Any access to the After The End is logged, therefore Plus Games collects any data regarding the usage and User journey of and through the game which cannot be deactivated by the user of After The End.
3. PURPOSE OF PROCESSING AND LEGAL GROUNDS

3.1 Purpose of data processing

In particular, but not limited to, and in accordance with the applicable law, Plus Games may process personal Data for the following Purposes:

  • In connection with products and services offered, conclusions of contracts, executions of contracts, maintenance and development of User relations, communication, Customer service and support, promotions, advertisement and marketing (including newsletters and mailing of promotional materials), communication, invitation to events and participation in promotions, organization of joint activities with Partners;
  • Management of the Users and other activities, operation, maintaining and developing After The End (including the provision of functions which require identifiers or other personal data) and additional IT systems;
  • protection of Users, employees and other individuals and protection of data, secrets and assets of and entrusted to Plus Games as well as the protection and security of systems and premises of Plus Games;
  • compliance with legal and regulatory requirements, including the internal rules of Plus Games, enforcement and exploitation of legal rights and claims, defense against legal claims, litigation, complaints, combating abusive conduct, engaging in legal investigations and proceedings and responding to inquiries of public authorities;
  • sale or acquisitions of business divisions, companies or parts of companies and other corporate transactions and the transfer of personal data associated therewith; and
  • for other lawful purposes where such processing was evident from the circumstances or indicated at the time of the collection.
(together the "Purpose of Data Processing").

3.2 Legal grounds of Data processing

Plus Games uses the personal data for the Purpose of Data Processing based on the following legal grounds:
  • performance of contracts;
  • compliance with legal obligations of Plus Games;
  • consent of User (can be withdrawn at any time);
  • legitimate interests of Plus Games, including but not limited to
  • purchase and rendering of products and services;
  • advertising and marketing activities;
  • efficient and effective User support, maintenance of contact and other communication with Users;
  • understanding User behavior, activities, concerns and needs, market studies;
  • efficient and effective improvement of existing products and services as well as development of new products and services;
  • efficient and effective protection of User data, secrets and assets of and entrusted to Plus Games as well as the protection and security of systems and premises of Plus Games;
  • maintenance and security, efficiency of business and development, Games and IT systems;
  • reasonable corporate governance and development;
  • compliance with legal and regulatory requirements and internal rules of Plus Games;
  • prevention of fraud, offences and crimes as well as related investigations, handling of claims and actions against Plus Games, legal proceedings, cooperation with public authorities, legal actions.
4. TRANSFER AND DISCLOSURE OF DATA

In accordance with applicable data protection laws, Plus Games may transfer personal data, to the following categories of commissioned data processors:

  • service providers;
  • dealers, retailers, suppliers and other business partners;
  • local, national and foreign authorities;
  • acquirers or parties interested in acquiring business units, companies or other parts of Plus Games;
  • other parties in potential or actual legal proceedings;
  • other Group companies of Plus Games.
(together "Commissioned Data Processors").

Plus Games may disclose personal data to Commissioned Data Processors and to any country worldwide, including namely all countries in which Plus Games is represented, affiliates or other offices and representatives as well as to countries in which service providers of Plus Games process their data. If data is disclosed to countries without an adequate protection, Plus Games shall ensure an adequate protection of the transferred User data or Partner Data (e.g. by EU standard clauses, binding corporate rules, EU-U.S. Privacy Shield Framework).
5. DATA RETENTION

In general, Plus Games retains personal data for no longer than it is necessary for the purposes for which the personal data are processed. Notwithstanding the general principle, Plus Games may process personal data for longer periods subject to the following rules and obligations: Plus Games retains personal data as long as Plus Games (i) is obligated to do so (by way of contract, law or other provisions) or (ii) has an overriding interest (e.g. an interest for reasons of proof in case of claims, documentation of compliance with certain legal or other requirements). Deviating rules are reserved with respect to anonymization or pseudonymization of personal data subject to applicable law.

Plus Games retains contract related personal data (including business records and communication) as long as the contractual relation is in force and for ten years after termination of the contractual relationship unless (i) a shorter or longer statutory storage obligation is applicable, (ii) the retention is required for reasons of proof or another valid reason based on applicable law, or (iii) the deletion of the data is required earlier.

Log files are retained for 12 months.
6. COOKIES, TRACKING AND SOCIAL PLUG-INS

6.1 Cookies

Plus Games don't uses cookies on its Website.

6.2 Analytic Tools

6.2.1 AdJust and Clever Ads Solutions

Plus Games uses the AdJust Tracking Service. Further information can be found in AdJust's data protection declaration at https://www.adjust.com/terms/privacy-policy/.

After The End is used to display CleverAdsSolutions (CAS) ads to users. Further information can be found in CAS's data protection declaration at https://cleveradssolutions.com/PrivacyPolicyCAS.html.

6.2.2 Google Tag Manager and Google Analytics

6.3 Social Plug-ins and Social Sign-Ups

If a login (Social Sign-Up) is offered via a social login service - e.g. Facebook Connect or Google - data is exchanged between the provider and After The End. With Apple Sign Up, for example, transferred data contains data from the public Apple ID profile of the User. By using such login services, the User expressly consents to the transfer of data to the respective provider.

The purpose and scope of the data collection and the further processing of the data by the provider as well as the relevant rights and setting options for the protection of privacy can be found in the privacy notices of the providers.

Google Inc.: https://policies.google.com/privacy

Apple Inc.: https://www.apple.com/legal/privacy/en-ww/


6.4 Other Tools and Applications

After The End uses BitLabs and AdJoe PlayTime as an Application to provide advertisement and allow to get free in-game currency. By using After The End, the User declares to agree the collection and processing of automatically processed data by AdJoe, BitLabs and third parties. If the user does not consent to the use of AdJoe and BitLabs, he loses access to part of the functionality of After The End app. Terms and Conditions of AdJoe can be found at https://adjoe.io/privacy/. Terms and Conditions of BitLabs can be found at https://bitlabs.ai/privacy-policy.
7. COMMISSIONED SERVICE PROVIDERS AND THIRD PARTIES

In order to ensure a convenient experience, Plus Games may cooperate with service providers (or third parties) for payment, Customer service, programming, testing etc. Using these service providers, Plus Games may transfers data to the following companies for the purpose described:

  • Google Play Store, Google LLC, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA; Distribution and Sales partner;
  • App Store, Apple Inc., One Apple Park Way, Cupertino, CA 95014, USA; Distribution and Sales partner;
  • Google Coud Services, Google LLC., 1600 Amphitheatre Parkway Mountain View, CA 94043, USA; Player Authentication and linked accounts, Storing and managing of player data;
  • Unity Technologies, 30 3rd Street, San Francisco, CA 94103, USA; Platform provider.
8. RIGHTS OF THE USERS, VISITORS AND PARTNERS

Any affected individual may request information from Plus Games if data concerning them is being processed. In addition, any affected individual has the right to request the correction, deletion or restriction of its own personal data as well as to object to the processing of its own personal data per se. Should the processing of personal data be based on consent, the affected individual may withdraw such consent at any time.

Request shall be submitted to

PLUS GAMES
35 RUE DES ALLIES
38100 GrenobleFrance
[email protected]

Plus Games reserves the right to restrict the rights of the affected individual in accordance with applicable law and e.g. not to disclose comprehensive information or not to delete data.

In the event that Plus Games makes an automated decision with respect to a certain individual which may have a legal effect for the affected individual or seriously affect him or her in a similar way, the affected individual shall have, in accordance with applicable law, the right to communicate with Plus Games and to request a reconsideration of the decision or to request the prior evaluation by Plus Games. In such case, the affected individual may no longer be able to use certain automated products and services. The individual will be informed thereof subsequently or separately in advance.
9. CHANGES TO THIS DATA PROTECTION POLICY

Plus Games reserves the right to amend this Data Privacy Notice at any time and without prior notice or announcement. Thus, you are advised to review this page periodically for any changes. Plus Games will notify you of any changes by posting the new Privacy Policy on this page. These changes are effective immediately after they are posted on this page.
10. PAYMENTS

Payments are not provided by Plus Games but only through third party providers. Plus Games does not collect and/or store any payment data such as credit card or bank account information or any other financial data other than the payment amount and date of the transaction itself as well as what product and/or service has been purchased. Any payment and the respective data are under control of the respective third party payment provider and the payment providers data protection policy shall unconditionally apply.

Plus Games does not take any responsibility whatsoever for such payment providers.
11. NEWSLETTER AND PERSONALIZED ADVERTISEMENT

If agreed upon by the User, Plus Games may send commercial communications regarding its products and services to the User. Based on the information provided, Plus Games may personalize the information provided to the User that the User only receives information that Plus Games deems interesting and relevant to the User. For this purpose, Plus Games analyses the data including but not limited to information about age, gender, interests and preferences as well as other information collected and data that can be derived from linking various data of the User and otherwise.

Plus Games may send commercial communications in connection with its products and services to Users. In accordance with the applicable law, Plus Games reserves the right to do so without the prior consent of existing Users.

The User may at any time unsubscribe from any newsletters or other commercial communications on the Website or via the link provided in each mailing. The termination of one newsletter may not entail the termination of other newsletters.
12. SECURITY

Plus Games value your trust in providing us your Personal Information, thus we are striving to use commercially acceptable means of protecting it. But remember that no method of transmission over the internet, or method of electronic storage is 100% secure and reliable, and we cannot guarantee its absolute security.
13. Children's Privacy

These Services do not address anyone under the age of 13. I do not knowingly collect personally identifiable information from children under 13. In the case we discover that a child under 13 has provided me with personal information, I immediately delete this from my servers. If you are a parent or guardian and you are aware that your child has provided us with personal information, please contact us so that we will be able to do necessary actions.
14. Contact Us

If you have any questions or suggestions about my Privacy Policy, do not hesitate to contact us at [email protected].
All rights reserved © PLUS GAMES, SARL
Identification Number (SIRET): 980 950 232 00010
Legal Address: 35 RUE DES ALLIES 38100 GRENOBLE FRANCE
[email protected]