Hereinafter, we refer to both the Apps and the Website as the “Services”.
In providing the Services, Command9 Studios acts as data controller, as defined in European Regulation n°2016/679, also known as the General Data Protection Regulation (the “GDPR”).
Please note that the scope of this Policy is limited to information and data collected or received by Command9 Studios through your use of the Services. Command9 Studios is not responsible for the actions of individuals with no relationship to Command9 Studios or third-party companies. Links to those websites available on the Website do not constitute our sponsorship of, or affiliation with, those individuals or companies.
When you visit the Website and access the services available we collect:
– Contact Information such as your name, address, the browser settings ;
– Data related to your application if you apply through the website (data on your Linkedin account, first and last names, current position, address, email address, phone number, profile picture, Cv and cover letter content, online presence, etc.);
– Data related to the game projects that you send us (first and last names, email address, Skype ID, name and relevant information of your studio, comments);
– Email address and data you send us through email ;
– When you post a comment: your email address, name and content of the comment.
When mandatory, the personal data are marked with a *.
When you send us an email:
The content of the email;
Your name and email address.
When you download, install and access our Apps, we collect information that help us identify your device, such as:
– the technical features of your terminal equipment and software, such as the browser settings, the installed plug-ins, the time zone, the screen size of your device, unique device ID, Advertising ID*, Device Identifier**, the type and version of your operating system (“OS”), and your general (city/country) location (based on your IP address);
– Gameplay data – session time, details of your in-app purchases (excluding your payment or credit card information), in-app events such as spending virtual currencies, progresses in the App, timestamp, etc.;
– We may occasionally send you push notifications through our mobile applications to send you game updates, high scores and other service-related notifications that may be of importance to you. You may at any time opt-out from receiving these types of communications by turning them off at the device level through your settings or by going to the settings for the app itself.
* Advertising ID means Apple Identifier for Advertisers (“IDFA”) on Apple and Google Advertising Identity (“GAID”). These are unique identifiers for mobile devices that advertisers use for personalized advertising. They are consistent across all mobile applications and thus allow cross-app tracking.
** Device identifier / information means device type, device model, device maker, device operating system and its language or other technical data like screen size or processor, or combination of this data available from a device for a developer for checking the device compatibility with a particular application.
On Apple, you can opt out of interest based advertising by selecting “limit ad tracking” option in your privacy settings. On Google Android, you can opt out of these ads by choosing “Opt-out of personalized ads”. Advertising IDs are non-permanent, non-personal identifiers, which are uniquely associated with your device.
Command9 Studios’s primary goals in using your information are to deliver the Services, enhance the Apps and the Website.
Therefore, Command9 Studios collects and processes your personal data in order to:
– Understand the Users and their preferences and provide new Apps’ content and services;
– Provide Apps’ updates, technical troubleshooting and to understand and analyze trends in connection with Users’ usage of the Apps;
– Respond/ publish to your comments and questions and provide customer service on both the Website and the Apps;
– Improve and optimize our Services, conduct research and create reports for internal use to make sure we provide you with the best experience;
– Communicate with Users about promotions, contests, rewards, upcoming events, and other news about the Services and services from our selected partners;
Conduct and administer contests promoted by Command9 Studios;
Deliver advertisements and promotional information in our Apps;
Cross promote our Apps and services on other apps and games;
Analyze gameplay data to improve the content and track potential problems or trends within our Apps, or to test our new Apps’ features and content;
– Process partners’ Apps’ projects through the Website or an email contact address;
– Receive and process job application to join Command9 Studios;
In addition, we use your information for our legitimate interest to promote our services in our Apps and also in other publisher’s apps and to display third-party advertisements to you.
Legal Bases for Processing
Under the data protection laws applicable, Command9 Studios must have a legal basis to process your personal data. The legal basis that applies in a particular instance will depend on the specific purposes for which Command9 Studios is processing your personal data:
– Consent: Command9 Studios will ask for your consent to collect and process your personal data in specific circumstances, notably, to process your contact requests and publish a comment on the Website. Should you choose to provide your consent, you may later withdraw your consent by contacting us as described in the “Your Privacy Rights”. Please note that the withdrawal of consent will not affect processing which has already occurred;
– Contract: when processing your job application or follow-up on a request for troubleshooting, for instance, Command9 Studios shall process your data as part of its obligations pursuant to a contract. You may not be able to opt-out of this processing, or your choice to opt-out may impact our ability to perform a contractual obligation otherwise owed to you;
Applicable law: in other instances, the processing of your Personal Data may be necessary in order to comply with any applicable law or regulation, such as ascertaining that you are older than 16 or under request from a supervisory authority or to protect our legal rights, investigate fraud, or to defend against a legal claim;
– Legitimateinterest: regarding in-game data collection and tailored advertising, we have identified that it is our legitimate interest to allow for the collection of the corresponding data to provide you with a better game experience and tailored adds, without monetary costs. Command9 Studios has chosen to provide Apps free of charge to its Users, and is willing to enhance and upgrade these Apps for no extra costs for the Users. The data we collect help us keep this model while offering you adds that are better suited to your taste. In order to balance our legitimate interests with your rights and liberties, we offer you to opt-out of this processing at any time (both when finalizing the game installation and when using the game)
In-app opt-out process: To opt-out, click on the button called “MOREINFORMATION” on the first two pop-up windows appearing when you connect to the game. When the third window appears, you should be able to unselect the tailored ads and analytics.
Inside the game, you may change your preferences in the main menu.
Depending on the legal basis for data collection, Command9 Studios may retain your personal data for various duration. As a general principle:
Data collected with your consent are kept until you request their deletion or for a twelve months period if we have no more contact with you after the Data collection;
Data collected for the provision of a contract are kept for the duration of the Contract;
Data collected to comply with a legal obligation are kept until this legal obligation has been fulfilled or the data are no longer required for its fulfillment;
– Data collected under the basis of our legitimate interests are kept for the duration of the provision of the related Services.
It is reminded that when consent is the legal basis of the data collection and processing, you may withdraw your consent at any time by contacting firstname.lastname@example.org. Withdrawing your consent does not affect the processing previously carried under this legal basis.
In some cases, specific duration may apply, for instance:
– Command9 Studios retains data pursuant to an application for one year from the day of reception, unless the applicant is hired in which case the data are kept for as long as he/she has a position within Command9 Studios;
– Command9 Studios retains data related to Users’ comments and requests for one year from the last contact;
– Command9 Studios retains all accounting and financial related data for a duration of 10 years.
In any case, after the original retention period, Command9 Studios may retain the data for 5 years, in the event that these data are needed to resolve any dispute before the competent courts and authorities, unless we are required by law to delete them.
The data collected through trackers and cookies are kept for a maximum of 13 months. Please report to the “Cookies” and “Data transfer to third parties” section for more information on how cookies are processed.
We do not knowingly collect or solicit personal data from anyone under the age of 16 or knowingly allow such persons to use our Services.If you are under 16, please do not send any information about yourself to us, including your name, address, telephone number, or email address, without the authorization of your parents. No one under the age of 16 may provide any personal data without such authorization.In the event that we learn that we have collected personal data from a child under the age of 16 without the authorization of the holder of the parental responsibility, we will delete those information as quickly as possible. If you believe that we might have any information from or about a child under the age of 16 without the aforementioned authorization, please contact us.
Transfer of Personal Data Outside of the European Economic Area
We may transfer information that we collect about you to affiliated entities, or to other third parties located in countries or jurisdictions which are not part of the European Economic Area.
We use the “Standard Contractual Clauses for the transfer of personal data to third countries” endorsed by the European Commission as adequate safeguards to secure the transfer of your data and their processing outside of the European Economic Area.
You can obtain a copy of these clauses by requesting them to the following address: email@example.com
In addition, we may transfer your personal data to a State which is not considered by the European Commission as offering a level of legal protection of personal data that is equivalent to the one in force in the European Union, if you have expressly consented to their transfer or if the transfer is necessary under one of the following conditions:
– safeguarding of your life;
– protecting the public interest;
– complying with obligations to ensure the establishment, exercise or defense of a legal claim;
– for the consultation, under regular conditions, of a public register which, by virtue of legislative or regulatory provisions, is intended for the information of the public and is open to consultation by the public or by any person proving a legitimate interest;
– performance of a contract between Command9 Studios and you, or pre-contractual measures taken at your request;
– conclusion or performance of a contract concluded or to be concluded, in your interest, between Command9 Studios and a third party;
– by decision of our supervisory authority (the Cnil – Commission nationale de l’informatique et des libertés)
Right of data subjects
The data subjects have the right to access, modify, rectify, suppress, delete and, if necessary, and, in specific situation, a right to portability, in accordance with the provisions of the law of 6 January 1978 in its version in force (Loi “informatique et libertés”), and in accordance with regulation n°2016/679 known as the General Data Protection Regulation (GDPR).
The right of access, modification, rectification, deletion and, when applicable, portability, provided for in the previous paragraph may be exercised by contacting dedicated department at the following email address: firstname.lastname@example.org
Command9 Studios has appointed Virtual DPO as its data protection officer. The DPO can be contacted directly through the “contact page” on its website : www.virtual-dpo.fr.
In the event of any difficulty in connection with the management of their personal data, the data subjects have the right to file a complaint with the CNIL or with any relevant supervisory authority.
In addition, users of the Website or of APP understand and acknowledge that in the event of transfer of their data to a third party, the exercise of their rights relating to the transferred data must be exercised directly with the third party concerned.
Data transfer to third party
Command9 Studios works with many partners to provide the Services.
– Apps’ access and session duration;
– How you interact with advertisement;
– Device make, model and operating system;
– Device properties related to screen size & orientation, audio volume and battery;
– Operating system;
– Name and properties of mobile application through which a consumer interacts with the Services;
– Country, time zone and locale settings (country and preferred language);
– Network connection type and speed;
– IP Address;
– Internet browser user-agent used to access the Services;
– Identifier for advertisers (IDFA).
– Serving Ads: To allow Publishers to offer advertising inventory in their apps, and Advertisers to bid on and display ads in that inventory;
– Auditing, researching, and analyzing data in order to provide, protect, and improve the Ad Services and to ensure that our technologies function properly.
In addition, we share data with providers of analytic tools which we use to analyze your use of the apps.
In a nutshell, we may share information we collect or derive from you with third parties for the following purposes:
– Performance of the Services on our behalf, including the ones referenced above under “Third Party Services”;
– Analytics and research purposes in order to analyze our games and their performances;
– Advertisement/ game-tailoring;
– Protecting our legal rights : for instance, in case of subpoenas, court orders, or other legal processes with the competent courts and regulatory authorities, as well as part of a business transfer such as a merger, acquisition, or a bankruptcy or to protect our or a third party’s legal rights, investigate fraud, or to defend against a legal claim.
– Gameanalytics – https://gameanalytics.com/privacy;
– Google analytics – https://www.google.com/analytics/terms/us.html –
– Firebase – https://firebase.google.com/support/privacy/;
– Appsflyer – https://www.appsflyer.com/privacy-policy/;
– Tenjin – https://www.tenjin.io/privacy/;
– Facebook – https://www.facebook.com/privacy/explanation;
– Mopub – https://www.mopub.com/legal/privacy/;
– Applovin – https://www.applovin.com/privacy/;
– Vungle – http://vungle.com/privacy/;
– Unityads – https://unity3d.com/legal/privacy-policy;
– Facebook Audiance Network – https://www.facebook.com/about/privacy/update?ref=old_policy;
– Adcolony – https://www.adcolony.com/privacy-policy/;
– Tapjoy – https://www.tapjoy.com/legal/#privacy-policy.
While we strive to protect the information provided to our Partners, we have no direct control over their use of the collected information.
To oppose your data being processed by one or several of our Partners, you may opt-out from the dedicated pop-up window when downloading a game or in-game.
Below, you will find a list of the cookies our partners may use to collect data on you.
Cookies may be automatically installed on your browser or your device when you access our Site. A cookie is an element that does not make it possible to identify a person but is used to record information relating to your browsing of our Site.
What cookies may be installed when you visit our Site?
The cookies that may be installed on your browser when you visit the Site are mainly intended to improve the ergonomics of the Site and to enable the use of the services available to visitors such as connecting to the user account or storing the contents of the basket.
Our partners may install cookies on your browser as well, under the same conditions.
How long do cookies last?
There are two types of cookies: session cookies and persistent cookies. Session cookies are created temporarily in the sub-folder of your browser when you visit a website. Once you leave the Site, the session cookie is deleted.
The persistent cookie files remain in the sub-folder of your browser and are reactivated once you visit the website that created that specific cookie. A persistent cookie remains in the sub-folder of the browser for the duration defined in the cookie file.
Generally speaking, a cookie is valid for a maximum of 13 months.
You may refuse all cookies. However, we cannot guarantee you a similar user experience.
How do I set and delete cookies?
– Microsoft Edge or Internet Explorer, go to: https://support.microsoft.com/fr-fr/kb/278835 ;
– Mozilla Firefox, go to: https://support.mozilla.org/fr/kb/activer-desactiver-cookies ;
– Google Chrome, go to: https://support.google.com/chrome/answer/95647?hl=fr ;
– Apple Safari, go to: https://support.apple.com/fr-fr/HT201265.
For a comprehensive approach on how we collect your personal data through cookies and whether these cookies are mandatory or optional, please refer to the following chart:
Changes to This Policy
We may update this Policy to reflect changes to our data and information privacy practices.
If we make any material changes we will notify you by means of a notice on the Services prior to the change becoming effective. We encourage you to periodically review this Policy for the latest information on our privacy practices. Please note that if Command9 Studios needs to adapt the policy to legal requirements, the new policy will become effective immediately or as required.