Privacy and Confidentiality Policy – Compliant with EU Directives

Tutti Frutti Games SAS's confidentiality policy is an integral part of the terms and conditions of the operating licence agreement issued by Tutti Frutti Games SAS to its users.

Tutti Frutti Games takes your privacy seriously and we are careful about processing your personal data. As part of the General Data Protection Regulation (GDPR) coming into force throughout the European Union, we are optimizing the terms of our privacy policy and are taking advantage of this legislation to introduce improvements that will benefit our users worldwide.

This confidentiality policy applies to the services, websites and mobile applications published by Tutti Frutti Games, including requests made to and answers from support and customer services.

If you disagree with the terms of this policy, please do not use the services published by Tutti Frutti Games. By using our services, you are agreeing to this policy.

Preamble

COLLECTION OF PERSONAL DATA ABOUT MINORS UNDER THE AGE OF 13

In compliance with the terms of the US Children's Online Privacy Protection Act of 19 October 1999 (COPPA), Tutti Frutti Games SAS does not collect data from minors under the age of 13. This regulation forbids all website owners from collecting personal data from children under the age of 13 without verifiable parental permission. Should Tutti Frutti Games SAS detect personal data about minors under the age of 13, this data will be immediately deleted.

LINKS TO THIRD-PARTY WEBSITES AND MOBILE OR WEB-BASED APPLICATIONS

Tutti Frutti Games SAS's websites and mobile or web-based applications may include links to third-party websites and mobile or web-based applications. Tutti Frutti Games SAS is not responsible for the privacy practices or content of these third-party applications and websites.

Data Collected and Received by Tutti Frutti Games

Personal Data

Email Address

Your email address together with a user ID enable us to:

  • send you the links when you make winnings directly accessible in digital format on our partners' websites
  • make your account secure when it is set up
  • make your account secure to prevent it from being hacked
  • ensure you can find your account, whatever terminal you are using
  • ensure you receive messages informing you of changes to the games and prizes
  • chat to you in the event of problems sending your winnings or technical issues
Postal Address

We collect your postal address:

  • your title
  • surname/first name
  • street number
  • additional information if necessary
  • postcode
  • town

This data is collected so that we can send your winnings. Generic title and postcode data is used for statistical purposes to optimize how our games are organized.

Other Data Collected Automatically

We receive the following via your phone:

  • Your phone's country
  • Your phone's language

This data enables us to set the application to your language, or to English by default.

Technical Data
  • the name of your device
  • the model of your device
  • the operating system of your device

This information enables us to ensure the application is compatible with your device's technical data and to check the following:

  • formatting of the application's graphics
  • compatibility of software versions
  • IP address whenever you log on
  • actions during the game
Geolocation

Your geolocation is only sent to us when the application is active.

This data is used to show you game activities and winnings linked to your location. For example, winning cinema tickets: if you are playing by a cinema, we will get you playing with cinema-themed objects.

We can use this data to optimize the creation of Interactive Virtual Panels.

Time and Calendar Data

This data is only collected whenever the application is active. This data is used for generic statistical purposes and can be used to check the veracity of winnings.

Statistics

We record analyses in applications published by Tutti Frutti Games and by using third-party services such as Google and Facebook Analytics. This enables us to understand how the applications are used, identify the origin of an application installation, and improve the service. Depending on your device's confidentiality settings, these analyses may collect your advertising ID. Analyses may also record technical data about your device or browser.

Service Providers

We may share your data with Tutti Frutti Games's third-party service providers. These service providers will only have access to the data they need to provide limited functions on our behalf. They are required to keep your data completely secure.

Partners

Tutti Frutti Games works with partners that supply prizes as part of marketing campaigns. In some cases, we may transfer data about you to these partners. You can ask us not to transfer any personal data to these partners by not agreeing to our protection of privacy policy.

Aggregated and Anonymized Data

We may aggregate and anonymize your data to provide statistical data. We may sell, authorize or share this statistical data.

Other Circumstances

In certain circumstances, we are required by law to disclose personal data.

We may disclose personal data if you give us your explicit consent to do so.

Applications and websites run by Tutti Frutti Games may display advertising. Depending on your device's or browser's confidentiality settings, ad tracking data may be shared with the advertising service. Tutti Frutti Games's advertising component will ask for your consent before using personal and tracking data.

Legal Grounds and our Legitimate Interests

We only collect and process your personal data if we have legal grounds to do so.

Legal grounds include the contract you have agreed to and consent.

If you have any questions about the legal grounds on which we collect and use your personal data, please contact our data protection officer – specifying the subject of your email in the header – at: .

Data Access

Data is processed by the relevant internal departments. Our partners may also have access to data.

Data Retention

Your content and personal data are retained for as long as you have your account, and for 10 years after the application is last deleted.

Deleting Your Personal Data

You can ask us to delete your account and all your personal data by emailing: . Your request will be processed within 30 days. You must email your request using the same email address as in your account.

Some data will become anonymous or anonymized once your account is deleted. This data may be retained and used in aggregate form to report service performance and activity. Search engines and some services may store a cache of all content you have made public over a much longer period; this is beyond our control.

Right to Alter or Correct Data

Most of your personal data can be altered, corrected and deleted in your application account.

Right to Object to, Limit or Restrict Data Use

You can ask us to stop using all or part of your personal data. For example, if we have no legal right to keep using it, or if it is inaccurate or unlawfully held.

Download Your Data

You can make this request by emailing: . We will provide you with your data.

Complaints

If you have a complaint, please email our support team or data protection officer – specifying the subject of your request – at: .

Data Transfer to Third Countries

The personal data we collect is stored and processed within the European Economic Area (EEA) but may sometimes be processed outside the EEA. We take all reasonable steps to ensure your personal data is adequately protected, that only minimal data is processed outside the EEA, and that your data is secure and processed in compliance with this confidentiality policy and using the same level of protection as required by the Privacy Shield Principles.

Changes to this Confidentiality Policy

Tutti Frutti Games may update this policy from time to time. Changes may be necessary due to regulations and standards changing over time, improvements we may make to the service, or changes to our company. We will post changes on this webpage. If we make changes that significantly modify your rights, we will ask you to confirm once again that you agree with our privacy policy.

Purpose of Processing

All this data is used to:

  • award prizes to winners
  • make your account secure
  • inform you of new prizes and activities
  • send you applications suitable for your mobile device
  • inform you of content changes
  • process data for statistical purposes to optimize how our games and prizes operate
  • send you applications in your mobile device’s language
  • send you the right information according to your location