Privacy policy

ARTICLE 1: PREAMBLE
The purpose of this Privacy Policy is to inform you about the manner in which your personal data is collected, processed, and used by Archel Play, a currently registered company (the "Company"), ("Archel Play" or "We" or "Us") and your rights and obligations regarding the protection of personal data in connection with your use of Archel Play websites (the "Sites"), video games ("Games") and applications ("Applications") published by the Company that are available on computers or mobile devices and which display a link to this Privacy Policy.
The Sites, Games and Applications are collectively referred to as the "Services".
Archel Play is responsible for the collection of personal data, which is accessible to all Archel Group companies.
By accessing or using the Services, you acknowledge that you have read and accept this Privacy Policy.
Information for minors: We keep the information you provide us (first name, surname, date of birth, e-mail address, postal address, telephone number) to be able to communicate with you about your account, to track your purchases, to help you resolve security issues that may affect your account and to send you information about our Services. When creating your account, We ask you to enter an account name and password: this account name and password will allow you to access our Services, including our Games. Warning: this account name and password must remain secret, never communicate them to other people. 
You have the right to access and correct your data. To exercise this right and obtain communication or deletion of information concerning you, write to us, with the help of your parents, either on our website via the contact form or by email contact@archelplay.com.

ARTICLE 2: COLLECTED DATA
2.1 The information you provide Us with
When you use our Services, you may be asked for certain personal data.
By "personal data", we mean any information enabling you to be identified directly or indirectly, by reference to an identification number or to one or more elements that are specific to you.
We do not ask for this information if you only visit our Sites, but you will not be able to access certain areas of these Sites, such as forums, without registering.
You will be informed, at the time of collection, of the optional or compulsory nature of the communication of the personal data We ask you for and of the possible consequences of the non-disclosure of this data.
2.1.1 When You create an Archel Play account (the "Archel Play Account"), We ask You to provide Us with the following information: account name, password and email address.
2.1.2 When making a purchase on our Sites, We ask for payment information. The information requested depends on the payment method you have selected. When you make your first purchase on our Sites, you must certify your Archel Play Account by providing us with the following information: title, surname, first name, date of birth, postal address, country of residence and secret question/answer. We keep a record of the purchases you make on our Sites: date, amount, item purchased, payment method used.
2.1.3 In the "Account Management" section of our Sites, you can view your Archel Play Account information, fill in information about yourself and change some of it. The information that you can enter in the Account Management section is the following: title, first and last name, date of birth, postal address, country of residence, secret questions/answers. If you fill in all this information in Account Management, your Archel Play Account will be certified. If you have already certified your Archel Play Account, you will be able to change some of this information.
Account Management also allows you to enter your mobile phone number, one or more secondary postal address(es), your preferences for receiving newsletters by email and commercial promotions by SMS, the language you would like us to use to communicate with you, your Ankabox email settings, a personalised description for your profile (visible to all users of the Sites).
2.1.4 When you contact our customer service (the "Support"), you must create a request via an online form. Depending on the subject of your request, you may be asked to provide certain information, including first name, last name, email address, and other information.

Account Management also allows you to enter your mobile phone number, one or more secondary postal address(es), your preferences for receiving newsletters by email and commercial promotions by SMS, the language you would like Us to use to communicate with you, your Ankabox email settings, a personalised description for your profile (visible to all users of the Sites).
2.1.4 When you contact our customer service (the "Support"), you must create a request via an online form. Depending on the subject of your request, you may be asked to provide a certain amount of information, including first and last name and email address. In some cases, we will ask you to prove your identity by providing us with official identification.
If this is your first request to Support, an email will be sent to you indicating that you need to create a support account so that your request can be processed. To do this, simply click on a link in the email. You will then be asked to provide a password, but this is not a prerequisite for creating a Support Account and processing your Request. However, you will need to do so if you wish to view the response.
2.1.5 When you participate in a competition, tournament, sweepstakes or survey, We may ask you for certain personal data such as your first and last name, age, postal address and email address.
2.2 Information We automatically collect when you use the Services
When you use the Services, We collect information about the Services you use and how you use them:
2.2.1 When you browse our Sites, We collect the following information: IP address, date and time of connection, interventions on the Sites and discussion forums, interactions with the Sites (pages visited ...), preferences (languages). We use cookies or other similar technologies to collect some of this information. Please refer to Article 5 for more information on cookies.
2.2.2 During the installation and use of our Games, We collect the following information: game data (log and history of all data exchanges, log and history of connections and in general, all data related to the actions carried out in the Games), data concerning your hardware and software configuration (during the installation of a game and in the event of a hardware modification of your computer), IP address.
2.2.3 When installing and using our Applications, We collect the following information: IP address, date and time of connection, information related to your mobile device (brand, model, operating system version, unique identifier of the device).
2.3 When you choose to connect to our Services using credentials used on a social network or gaming platform
The Company may offer you the ability to connect to certain Services using a social network or gaming platform identifier. This method of connection will sometimes be required to access certain features of the Services, including providing you with the ability to interact with other users of such networks and platforms.
By logging in using a social network or gaming platform, you will be asked to agree to certain data about you being shared with Archel Play. By agreeing to this sharing of information, Archel Play will have access to this data and will retain some of it.
For example, by connecting to some of our Applications via the social network Facebook, Archel Play will have access to your friends list but will not retain it. This access allows us to provide you with certain social network features involving other users. We retain your Facebook ID to allow us to recognize you on multiple mobile devices and to reassign the progress you have made on your previous connections.
When you allow our Services to interact with social networks or gaming platforms, We may share data about you with your contacts. This data includes your name, your profile picture on the relevant social network and your progress and/or ranking in our games.
These social networks and gaming platforms are created and managed by third parties and are not controlled by Us. We invite you to consult their terms of use and privacy policies to understand how these third parties process your data and the data they may communicate to Us.

ARTICLE 3: AIMS AND LEGAL BASES
Your personal data may be processed for different purposes and on different legal grounds:
3.1 We use your data because it is necessary for the proper performance of a contract between you and Us. Thus, your data is processed :
for the creation, management and follow-up of an Archel Play Account;
to enable you to access and use the Services;
to enable you to purchase products and services on our Sites and to enable us to process, manage and track your orders;
to enable you to communicate with other users of the Services, in particular on our chats, discussion forums or via Ankabox ;
to send you important information about the Services and any other information related to your Archel Play Account and the actions taken with it (e.g. order confirmation emails, emails/SMS in case you forget your password, emails allowing you to activate Archel Play Shield protection);
for the management of complaints and after-sales service;
to assist you in case of technical problems when using our Services.
3.2 We use your data on the basis of our legitimate interests where these do not interfere with your rights and freedoms. Thus, your data is processed :
to improve our Services, in particular to improve the performance and experience of the Games or to manage bugs ;
to ensure the security of your Archel Play Account;
to offer you commercial activities such as contests, lotteries or tournaments;
to prevent and detect irregular behaviour and in particular to fight against payment fraud;
to control and monitor behaviour in the Games and to ensure compliance with the rules set out in our General Terms of Use, our General Terms of Sale and in any other text that you accept when using our Services;
to customize and improve the advertisements that We display through the websites and services of third parties;
to measure the performance of our marketing campaigns.
As part of the fight against payment fraud and cheating, automated decisions may be made based on your interactions with the Services and the data you provide to us. In particular, We may restrict or suspend your access to our Services (including through sanctions on your Archel Play Account) if such automated processing detects a user or activity that We believe presents a risk of fraud or cheating.
3.3 We require Your consent to send You commercial solicitations and newsletters by email and/or SMS.  
Please note that you may withdraw your consent at any time, without prejudice to the lawfulness of the processing based on the consent given prior to withdrawal. To do so, you can go to your Account Management to set your preferences for receiving commercial solicitations and newsletters. Our emails and SMS messages also contain a link or keyword to be sent allowing you to unsubscribe.
3.4 We process some of your data where this is necessary to meet our legal obligations (for example, to meet our accounting and tax obligations or where we are required by law to retain certain data).

ARTICLE 4: COMMUNICATION OF PERSONAL DATA
Archel Play may use third party service providers who will collect your personal data on behalf of Archel Play or with whom Archel Play will share your data in a secure manner, in particular for the purpose of carrying out tasks necessary to complete your order, the delivery of products, the processing of your payments, to ensure the management of customer relations, to provide you with a chat service, to fight against fraud in means of payment, to provide advertising services, to send you SMS messages (for the recovery of your identifiers in particular) or to offer you surveys.
These service providers may be located outside the European Union, in particular in Asia Pacific and in North and South America. Archel Play has taken all necessary steps to ensure that your personal information is adequately protected, either by using the standard data protection clauses established by the European Commission, or by ensuring that these transfers are made to US companies that have adhered to the principles of Privacy Shield.

Archel Play may also disclose your personal data to the competent authorities, at their request, in connection with legal proceedings, legal research and requests for information from the authorities or in order to comply with other legal obligations.

ARTICLE 5: COOKIES
When a person visits our Sites, cookies or similar files may be installed on the hard disk of the user's computer.
5.1 What is a cookie?
A cookie is a small file installed on your hard disk by the server of the site you are visiting.
It contains several data :
the name of the server that deposited it ;
an identifier in the form of a unique number;
possibly an expiration date.
This information is sometimes stored on your computer in a simple text file that a server accesses to read and record information.
There are different types of cookies:
session cookies, which are deleted when the session is closed,
the persistent cookies that are kept,
flash cookies.
You will find more information on cookies on the CNIL website (http://www.cnil.fr/vos-droits/vos-traces/les-cookies/) and on the http://www.allaboutcookies.org/ website.
5.2 Cookies deposited on our Sites
The cookies We use on Our Sites are distributed as follows:
5.2.1 Strictly necessary cookies: these cookies are essential to the functioning of our Sites and to provide you with the services requested. The purpose of these cookies is to allow your identification, to contribute to the security of our Services, to access your Archel Play Account and to manage your orders.
5.2.2 Functionality cookies: these cookies are intended to improve your navigation on our Sites. They allow us to remember your choices and preferences, such as language, to remember previous information you have entered so that you do not have to re-enter it on your next visit, and to remember which pages you have already visited so that you do not have to re-enter it again.
5.2.3 Audience and advertising measurement cookies: these cookies allow Us to measure the effectiveness of an advertising campaign on our Sites (number of views, number of clicks, etc.) and help Us to personalize the advertisements promoting our Services displayed on third party sites (targeted advertising). In addition, a tool for analyzing and exploiting events occurring following the sending of e-mails such as message openings, clicks, unsubscriptions and operating with the help of cookies is used, for statistical purposes in particular.
For this purpose, the Company uses Google Analytics, a web site analysis service provided by Google Inc. ("Google"). Google Analytics uses "cookies", which are text files placed on your computer, to help the website analyze how users use the site. The information generated by the cookie about your use of the website (including your IP address) will be transmitted to and stored by Google on servers in the United States. Google will use this information for the purpose of evaluating your use of the website, compiling reports on website activity for website operators and providing other services relating to website activity and internet usage. Google may also transfer this information to third parties where required to do so by law, or where such third parties process the information on Google's behalf, including but not limited to the publisher of this website. Google will not associate your IP address with any other data held by Google. By using this website, you consent to the processing of data about you by Google in the manner and for the purposes set out above. You can find out more about how Google uses your data when you visit our Sites: http://www.google.com/intl/fr/policies/privacy/partners/.
We also use Google Analytics to collect certain demographic data (age, gender) about visitors to the Sites and their interests on an anonymous basis. For this purpose, We use both proprietary cookies (such as the Google Analytics cookie) and third party cookies (such as the DoubleClick cookie) in conjunction with third party vendors, including Google. Archel Play uses this data in order to better understand the profile of users of its Sites. This information does not allow us to identify you. In addition, this demographic information cannot be combined with any personal information you may have provided to Archel Play.

5.2.4 Cookies intended to improve the interactivity of the Sites and to enhance the user experience: our Sites rely on certain services offered by third party sites. These include in particular :
chat services (Iadvize)
share buttons (Facebook, Instagram)
social network feeds (Instagram, Facebook and YouTube)
information on communication tools (Discord)
videos posted on our Sites (YouTube)
of geolocation services (Google Maps)
of services offering GIFs (Giphy)
5.2.5 Flash cookies: In certain situations, We may use local shared objects, commonly known as "Flash cookies", to store certain information, including your progress in browser games offered by the Company.  Flash cookies differ from browser cookies in the amount and type of data stored and how they are stored. Cookie management tools available on your browser will not delete Flash cookies. You can access your Flash management tools directly from Adobe's website: http://www.macromedia.com/support/documentation/fr/flashplayer/help/settings_manager.html. Please note that by disabling Flash cookies, you will no longer have access to certain features that facilitate your experience on our Sites.
5.3 Cookies set by Us on sites where our advertisements are present
On third party sites, advertising banners promoting the activities of Archel Play entities may be inserted. In this context, when an Internet user clicks on these banners, a cookie is installed in your terminal. These cookies are used :
to count the number of displays and activations of our advertising content on third party sites, to identify such content and sites, to determine the number of users who have clicked on each piece of content.
to calculate the sums due to the players in the advertising distribution chain (publisher of the third-party site and advertising network) and to draw up statistics
to track your device's subsequent navigation on our Sites.
5.4 Cookie management
During your first visit to our Sites, a banner informs you of the presence of audience and advertising measurement cookies and cookies intended to improve the interactivity of the Sites and enhance the user experience, and invites you to indicate your choice. You may at any time set your cookies to accept or refuse them by going to the "Cookie Management" page at the bottom of each page of the Sites. You will be able to indicate your preference either globally for the Sites or on a per service basis. 

ARTICLE 6: CHAT ROOMS AND USER PROFILE
The Services may contain discussion areas, including forums or chats. You also have the ability to customize your user profile. Archel Play reminds you that all personal information disclosed in forums, chats and profiles becomes public information that can be reused by anyone. Therefore, users should be careful if they plan to communicate personal data on this type of service.
In any case, Archel Play advises you not to publish sensitive and personal information and in particular data that reveal your racial or ethnic origins, political opinions, philosophical or religious beliefs, or trade union membership, as well as genetic, biometric and data concerning your life or sexual orientation.
If you choose to post such information on our Services, you agree that such information may be visible to other members, as well as to anyone accessing the Services.
Therefore, please do not indicate any information that you do not wish to be made public.

ARTICLE 7: SECURITY
The Company implements the appropriate technical and organisational measures, in view of the nature of the data and the risks presented by the processing, to guarantee a high level of data security and, in particular, to prevent the data from being distorted, damaged or accessed by unauthorised third parties.
For example, Secure Socket Layer (SSL) technology is used to encrypt certain data, physical and logical data back-up procedures are implemented and a protocol to secure access by encrypting data (HTTPS) is used.
The Company reserves the right to take legal action against any person attempting to access personal information that does not concern it.

ARTICLE 8: THIRD PARTY WEBSITES
Hypertext links on the Services may take you to sites that are not owned by Archel Play.
Please be aware that the privacy policies of these different sites may differ from this Privacy Policy. In any case, we recommend that you read the personal data protection policy of each of these sites.
In any event, Archel Play shall not be held liable in the event that the content of such site(s) contravenes any applicable legal or regulatory provisions or this Privacy Policy.

ARTICLE 9: YOUR RIGHTS
Unless otherwise stated, You may exercise Your rights under this Article :
Either via online support,
Either by sending an email: contact@archelplay.com
In the interest of confidentiality and the protection of your personal data, We must ascertain your identity before responding to your request. Also, any request to exercise your rights must be accompanied by a copy of a signed identity document.
Your request will be processed as soon as possible, in accordance with the legal provisions in force.
9.1 Right of access and right of portability: You have the right to obtain confirmation as to whether or not personal data concerning you is processed by Archel Play and, if so, access to such data and information relating to its processing. You may also, where technically possible, exercise your right to portability.
9.2 Right of rectification: You have the right to obtain the rectification of any personal data concerning you which is inaccurate or incomplete (and which you cannot rectify yourself in your Account Management or via the mobile services made available by Archel Play).
9.3 Right to Deletion: We will retain your personal data for as long as necessary for the fulfilment of the purposes set out herein. If you no longer wish Us to process your data, you may ask Us to delete it and close your Archel Play Account. Please note, however, that even if you exercise this right, We may retain some of your data for the following purposes:
We may retain some of your data to protect our legitimate interests, such as the detection and prevention of fraud;
We may retain and use your data to comply with our legal obligations;
If you have posted comments on our Sites or intervened on our discussion forums, your comments and interventions will always appear but will not be attributed to you.
9.4 Right to Limitation of Processing: You have the right to obtain a limitation of the processing of your data, in limited circumstances : (i) when you challenge the accuracy of your data; (ii) when the processing is unlawful and you request the limitation of their use instead of their deletion; (iii) when We no longer need your data for the purposes of processing but they are still necessary for the establishment, exercise or defence of legal claims; (iv) when you have objected to the processing under Article 9.5, while verifying whether the legitimate grounds pursued by Archel Play prevail over yours.
9.5 Right to Object: You may object at any time, for reasons relating to your particular situation, to the processing of your data where such processing is based on a legitimate interest. If you exercise this right, We will no longer process your data, unless We can demonstrate that there are legitimate and compelling reasons for the processing that prevail over your interests, rights and freedoms, or for the establishment, exercise or defence of legal claims.
You may object at any time to the processing of your data for canvassing purposes. Your preferences for receiving commercial solicitations and newsletters by email and/or SMS can be configured in your Account Management. Our emails and SMS messages also contain a link or a keyword to be sent allowing you to unsubscribe.

ARTICLE 10: DATA RETENTION
We keep your personal data for as long as necessary for the fulfilment of the purposes set out herein, in compliance with the legislation in force. To know your rights to erasure, please consult the article "Your rights".

ARTICLE 11: UPDATING
We reserve the right to change this Privacy Policy at any time. Therefore, We invite you to consult our "Privacy Policy" on a regular basis.
Last modified: January 2020

ARTICLE 12: QUESTIONS AND COMPLAINTS
If you have any questions or complaints about our Privacy Policy, you can contact Us :
by email: contact@archelplay.com
You can also contact our data protection officer at the same addresses.
If, however, you consider that we have not met your expectations, you have the possibility to lodge a complaint with a competent data protection supervisory authority.