PRIVACY POLICY

Protection of its users’ personal data and privacy is of great importance for Elokence SAS (“Elokence”, “we”, “us”, or “our”). To that purpose, Elokence commits to carry out processing of personal data in compliance with applicable data protection laws and regulations in the countries from which its users access and use the Akinator mobile applications (“App”), including in particular the European General Data Protection Regulation (known as « GDPR »).

This Privacy Policy clarifies how we collect and process your personal data in the context of your use of the App. Please read it carefully as it is applicable each time you are using the App.

You will find relevant information in this respect under the following categories:

  1. WHAT IS PERSONAL DATA?

Personal data means any information relating to an identified or identifiable natural person (the “data subject”).

In the context of your use of our App, you are considered as data subjects. Personal data covered by this Privacy Policy are therefore all and any information relating to you, to the extent that you are identified or identifiable, for instance by reference to the IP address of your device or your account credentials.

Processing of personal data is subject to specific legal and regulatory provisions, in particular the GDPR.

  1. WHY DO WE COLLECT YOUR PERSONAL DATA?

We only collect your personal data that are necessary to pursue purposes such as ensuring you have the best experience with the App, easily communicating with you, providing you with personalized advertising and, in some circumstances and based on your consent, sharing your personal data with our partners.

  1. HOW IS MY PERSONAL DATA CONCERNED?

We collect your personal data in the following situations and for the purposes detailed hereafter:

  1. When using the App

Upon connecting to the App, we will collect the following personal data:

  • The IP address of your device;
  • The model of this device;
  • The advertising ID;
  • The device ID;
  • The system language;
  • The network used;
  • The identified country;
  • The App version ;
  • The business model of the App;
  • The App language selected;
  • The geolocation data ;
  • Technical data relating to your device;
  • Personal data you might communicate to us when creating a character on the App (display name, picture, description of the character, language, etc.);
  • And all relevant data related to events within the App.

This data will be collected and processed for the purpose of allowing correct display of the App on your device. This processing is based on its necessity for performance of a contract to which you are a party, namely the Terms of service of the App.

If you have consented to the use of the relevant categories of IDs as described under Article 6 hereunder, we will also be able to collect data relating to your use on the App, such as visited contents, through these IDs in the context of such use.

This data will be collected and processed for the purpose of measuring the audience of the contents of the App. This processing is based on our legitimate interest in getting to know the users of our App better in order to improve the App.

Geolocation data may also be processed for the purpose of serving targeted advertising on the App. This processing is based on your consent. At any time, you can oppose both the activation and the operation of this collection by disabling it in the “location services” settings of the App on your device (settings might be different whether it is an Android or iOs system).  

  1. Upon registering/using your account on the App

Upon registering/using your account on the App, we will collect, through the registration form, the following data:

  • Your display name;
  • Your e-mail address;
  • The secured version of your password.

This data will be collected and processed for the purpose of managing your user account, providing the App services to you, identifying or reidentifying your device to offer you targeted contents and advertising. This processing is based on its necessity for performance of a contract to which you are a party, namely the Terms of service of the App.

  1. When using the “Leave a message” form

When using the “Leave a message” form on the App, we will collect, through that form, the following data:

  • Subject of your message;
  • Your e-mail address;
  • The message you write in the field “Description”;
  • Any screenshot you may attach to your message;
  • Data linked to your account and technical data linked to the context of use to help us to understand the problem you may encounter.

This data will be collected and processed for the purpose of Elokence receiving and processing your message, and being able to answering it and fix any problem you may encounter described in your message. This processing is based on your consent, as expressed through clicking on the “Send” button of the “Leave a message” form.

In case your message should contain personal data classified as “sensitive data” under the applicable data protection laws and regulations, for instance data relating to your health condition, you will consent explicitly, through clicking on the sending button of the contact form, to Elokence receiving and processing such data for the purpose of answering to your message. It is understood that Elokence does not require or encourage its users to communicate sensitive data through the “Leave a message” form.

Please note that when you purchase on the App, Elokence does not collect, process or store your payments data. Payments made from our App are managed by a secured service provided by a third party.  

  1. WHO IS THE DATA CONTROLLER AND CAN I GET IN TOUCH?

The data controller for the aforementioned processing activities is Elokence which provides the App.

Should you have any question or concern regarding this Privacy Policy, processing of personal data by Elokence on the App or more generally Elokence’s commitments in terms of data protection and privacy, you may contact the Privacy Policy Administrator by sending an email via privacypolicy@elokence.com or by writing to Elokence SAS, Attention: Privacy Policy Administrator, 10 Avenue Gustave Eiffel, Chartres, France.

  1. WITH WHO IS MY PERSONAL DATA SHARED?

Personal data collected and processed as described under Article 3 here above will be shared with the persons and services within Elokence on a need-to-know basis only, namely in particular our staff dedicated to technical issues and user experience studies.

In some specific cases only, your personal data may be shared to answer to competent authorities’ requests and in legal proceedings if necessary.

Your personal data may also be indirectly collected by our partners (google analytics, firebase, typeform and advertising partners) to the extent necessary for fulfilling the purposes described under Article 3 here above.

Your personal data may also be shared with our partners in order to provide you with targeted contents and advertising. These partners may combine these data with other personal data you may have provided to them or they may have collected while you used their own services.

We do not transfer your personal data outside the European Union: all our servers are located within the European Union and your personal data will be stored within these servers. In cases where your personal data would be indirectly collected by our partners and then transferred by them outside the European Union, we invite you to revert to their own privacy policy to know how they secure the transfers of your personal data outside the European Union.

  1. HOW LONG IS MY PERSONAL DATA RETAINED? 

Personal data collected and processed as described under Article 3 here above will be retained by Elokence for no longer than necessary to fulfil the purposes described under that Article 3. In particular, we will retain your personal data the time required to provide you access to the App and, if applicable, to answer to Elokence’s legal obligations.

  1. HOW ARE IDS AND SIMILAR TECHNOLOGIES USED?
  1. What is an ID?

IDs are pieces of information (mainly advertising IDs) that an application transfers to an individual's storage for record-keeping purposes. IDs make app-use easier by saving use patterns while you are using the App.

  1. How are IDs used?

IDs may be used to:

  • Analyse your use of the App;
  • Improve contents;
  • Customize the App's content and layout;
  • Improve and personalize your experience on our App;
  • Serve targeted advertising on the App.

These IDs may be emitted by Elokence and its partners. The App may also use IDs and/or similar technologies for the sole (purely technical) purpose of allowing you to connect and access the App.

You may object to the storage and access of the IDs on your device by using the appropriate settings of your device. Please note however that IDs are an important part of how our App work; therefore, we draw your attention to the fact that if you choose to refuse some IDs, this may, in some cases, preclude you from using, or negatively impact the display or function of, the App or certain areas or features of the App.

  1. WHAT ARE MY RIGHTS?

Pursuant to the applicable data protection laws and regulations, you dispose of the following rights regarding processing of your personal data: right of access, right of data portability, right of correction, right to erasure, right to object to processing and right to limitation to processing.

You may exercise these rights by contacting the Privacy Policy Administrator at privacypolicy@elokence.com or by writing to Elokence SAS, Attention: Privacy Policy Administrator, 10 Avenue Gustave Eiffel, Chartres, France.

These rights being purely personal, they may only be exercised by the data subject themselves. Therefore, you may be asked to provide a copy of a valid ID document to your request; we will only retain that copy for the time necessary to verify your identify.

If that personal data has been shared with third parties, Elokence will inform these third parties of your request for erasure, to the extent that it is feasible. Elokence will in such case cease to process the concerned personal data and retain it for the appropriate duration.

For those of the processing activities described under Article 2 here above based on your consent, you have a right to withdraw that consent at any time, without justification.

Last, you have a right to lodge a complaint relating to the processing of your personal data by Elokence with the competent supervisory authority in your country.

  1. HOW IS MY PERSONAL DATA SECURED?

We take reasonable measures to protect Personal Data from misuse, loss and unauthorized access and in particular we have physical, electronic, and procedural safeguards in place to protect Personal Data. In addition, Personal Data is stored on our servers and protected by secured networks to which access is strictly limited to a few authorized employees and personnel. You have however to be aware that, due to its own characteristics, the use of the Internet is not 100% secured.

  1. THIRD-PARTY WEBSITES OR APPLICATIONS

You may download the App from another website. In addition, our services provided through the App may contain links that will let you leave our App and access another website or application. Such websites or applications are not under the control of Elokence and it is possible that these websites or applications have a different privacy policy than ours. Our Privacy Policy applies solely to Personal Data collected by your use of our App and we are not responsible for these other websites. We urge you to be careful when using your Personal Data online.

  1. MODIFICATION OF THIS PRIVACY POLICY

This Privacy Policy was last updated on September 9, 2019. Please note that we may revise it from time to time and that we reserve the right to update or modify it.

We will display the revised Privacy Policy on the App, so that users can always be aware of what personal data we collect and how we collect it. In addition, if you registered under the registration form, you will also receive an email informing you of modifications or updates of the Privacy Policy on the email address associated to your user account.