PRIVACY POLICY (Last Updated: May 2022 with effective date 19 May 2022)

Please read this Privacy Policy carefully to understand our policies and practices regarding your Personal Data (as defined below) and how we will treat it.

This Privacy Policy applies to Sudoku.academy website. This Privacy Policy explains how we, and affiliated companies collect, use, secure, and/or disclose end-users’ (“you” or “your”) or otherwise processes your personal information when you use our Services.

The data controller is Savate, with a registered address at 29 Rue Pierre Curie, 77290, France.

INFORMATION WE COLLECT AND HOW

While using our Services, we may ask you to provide us with certain personal data or personal information that can be used to identify you (“Personal Data”, or “data” or “information”). We may also collect Personal Data automatically, or from third-party partners or services. The Personal Data we collect includes:

Basic Identifiers and Contact Information

We collect some information from you when you provide it to us directly, such as via an email or online form, through the support feature embedded in our Services, or through another form of inquiry. This information may include your name, email.

Device Information

When you download and use our Services, we automatically collect information on the type of device you use, operating system, resolution, application version, mobile device identifiers (such as your device ID or advertising ID), language, time zone and IP address.

Usage Information

We collect information automatically about your activity through our Services (Usage Information), such as the date and time you used a service, features you have used, subscriptions, your interaction with advertisements, and data generated when you use our Services (for example your game progress which may be stored).

Location

When you download and use our Services, we automatically detect your general location, namely country and state through your IP address. We may collect, with your consent if applicable, other location information through your IP address, such as the city you are in.

Cookies and similar data collection technologies

We and our third party advertising networks and their partners may use cookies, to provide and personalize our Services and to provide targeted advertisements. Some of these technologies can synchronize behavior across different mobile apps, devices and websites so that advertisements can be tailored to your interests. This process is called personalized advertising.

For more information on how third parties may use tracking technologies in our apps, go to APPENDIX A and APPENDIX B further below.

For more information on the use of cookies on our websites can be found at the cookie policy page

PURPOSES FOR WHICH WE WILL USE YOUR PERSONAL DATA

We have set out below a description of the ways in which we use your Personal Data, the legal bases we rely upon to do so and to provide you with an option to opt-out of certain practices, where applicable. We may use your Personal Data:

  • To provide and maintain our Services, recognize you when you return to our apps, to sync your progress across devices when you log in to your account with third parties and perform essential business operation, our legal basis for processing is performance of a contract with you which you entered into with us when you accept our End User License Agreement.

  • To administer and protect our Services (including troubleshooting, data analysis, testing, support, fraud, reporting and hosting of data). Our legal basis for processing is legitimate interests for running our business, provision of administration and services.

  • To use user generated content which has been provided by you and such content includes Personal Data. Our legal basis is consent which is obtained directly by you from the medium (e.g. e-mail) used to obtain such content.

  • To respond to legal proceedings and other obligations or requirements under applicable law.

RETENTION OF PERSONAL DATA

We will retain your Personal Data only for as long as is necessary for the purposes set out in this Privacy Policy. We will retain and use your Personal Data to the extent necessary to comply with our legal obligations (for example, if we are required to retain your data to comply with applicable laws), resolve disputes, provide our Services and enforce our legal agreements and policies.

We will also retain Personal Data and Usage Information for internal analysis purposes and legitimate business interest to the extent necessary to improve the functionality of our Services, for business purposes or when we are legally obligated to retain this data for longer time periods.

Your Personal Data collected through our Services will be retained for as long as permitted by applicable law or necessary depending on the respective purpose of collection and shall be deleted when they no longer serve one of the above-mentioned purposes or shall be anonymized and therefore will no longer constitute Personal Data. It is clarified that in no case the retention period should exceed the 5 years from the date of collection. Once we have deleted or anonymized your Personal Data, you will not be able to exercise the right to access, the right to erasure, the right to rectification or the right to data portability.

YOUR RIGHTS AND OPTIONS

Access Personal Data we hold about you

You have the right to request access to your Personal Data collected through our Services. Following your request, we will provide you a copy of your Personal Data in an electronic format.

For Personal Data simply send us your data access request by sending an email to privacy@sudoku.academy.

Other rights

You also have other rights such as to correct your data, have your data deleted, object how we use or share your data, and restrict how we use or share your data. You also have the right to withdraw consent where you have previously given your consent to the processing of your Personal Data, for example by turning off camera access in your mobile device settings. This will not affect any data processed before such withdrawal.

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