Privacy Policy

 

1- PURPOSE:

Marketluck collects information about you when you use our mobile applications, websites, and other online products and services (collectively, the "Services") and through other interactions and communications you have with us. The Services are provided by Marketluck.

Marketluck is committed to ensuring that your privacy is protected. Should we ask you to provide certain information by which you can be identified when using this website, then you can be assured that it will only be used in accordance with this privacy statement.

In this respect, we respect the following principles: - We collect the data we need - We process your data for explicit, legitimate and specified reasons - We keep your data for the time it takes to process it for the purpose for which it was collected, or, if such is the case, for the time stipulated by law - Any data collected is shared only with Marketluck and any of its service-providers that need such information in the context of our activities - We make sure that all appropriate security measures are implemented in order to ensure a high level of protection for your data The aim of our Confidentiality Policy is to inform you in a transparent manner about how we collect and use your data and about your rights.

2- SCOPE AND APPLICATION :

Our Confidentiality Policy applies to all our websites and applications. By using our services you accept the terms of this Policy. This Policy is subject to modification at any time; we therefore recommend that you consult this page on a regular basis. This policy has been applicable since 3 May 2016; additional information was added and amendments were made on 06/04/2020.

3- RESPONSIBILITY FOR DATA PROCESSING:

The body responsible for processing your personal data is MARKETLUCK SAS, 13-15 Immeuble Plainespace, 13 Avenue de la Métallurgie, 93210 SAINT DENIS, France - a company registered in the Bobigny Trade and Companies Register under number 803 829 688 and represented by its president, Madame Isabelle Bellino.

Which personal data are collected :

On our mobile app:

Information You Provide to Us : We collect the information that you provide directly to us, for example, when you create or modify your account.

This information may include: name, email address, telephone number, postal address, profile photo and other information that you choose to provide.

Email communications : We shall write to you by email to verify the validity of your account when you provide us your email address upon registration, and when you win a prize, and we may send you occasional communications about new Services. You may not unsubscribe from emails that are necessary to the due fulfilment of our Services, however, you may opt out of receiving additional emails about services by withdrawing your permission at any time. Provided that you have given us your permission to do so, we may also send you promotional messages from our partners.

Informations you share : Any information that you share with other people is considered to be public and shared at your own discretion.

Social sharing features :

Our services may incorporate social sharing functionality and other related tools that allow you to share your activity on our services with other applications, websites or media, and vice versa. Using these features allows you to share information with your friends or the public, according to your chosen settings on the social sharing services.

For more information about how they process the data that you provide or share, please consult the privacy policies of these social sharing services.

Using these features allows you to share information with your friends or the public, according to your chosen settings on the social sharing services.

For more information about how they process the data that you provide or share, please consult the privacy policies of these social sharing services..

Information obtained from your accounts with third-party services : You may send us information via third-party services, for example, Facebook Connect, to facilitate the creation of your account on our Services. This allows us to collect the necessary data to complete your profile even faster. We shall never receive your passwords from Third-Party Services, and we shall only interact with these latter by means of an identifier or Token that is valid for a limited time.

Information that we obtain from third-party services: we may be required to obtain information from third-party services as necessary for the due fulfilment of our Services, for example, the country of origin associated with an IP address, which enables us to restrict access to the Services to authorised countries only.

Information about the use of our Service : we collect information about the way in which people use our Services. This type of information may be collected in our log files each time that you interact with our Services, for example, when you visit a page or browse through an application.

We use internal tools, as well as third-party applications and services (such as Google Analytics or Firebase), to collect and analyse this information. Some of this information may also be linked to the Internet Protocol address (“IP address”) used to access the Services.

In addition, some of the information may be linked to your Account, and other information may only be collected and used in aggregate form (as statistical data that does enable you, nor your Account, to be identified).

We may use the information about the way in which you or other people interact with our Services for a variety of purposes and, in general, to optimise, improve and protect our Services, as well as to develop new Services, including but not limited to: for the purposes of providing users with personalised content and targeted advertisements, improving our research activities, identifying the most popular Services, and for legal and security purposes.

Information concerning your mobile device : We may collect and store information about your mobile device. In certain cases, we may receive, generate or attribute a unique identifier for your mobile device, obtain the technical specifications of your telephone, including the model and screen resolution, or obtain the list of installed applications. This information shall be used for the purposes described under “Information about the use of our Services” or “Information relating to targeted advertising”.

Information concerning targeted advertising : we may use information such as mobile advertising identifiers (Apple IDFA or Google AAID, which are technical identifiers developed by mobile operating systems for advertising purposes; they remain under your control and you can reset or delete them at any time in your device’s settings), your gender or your favourite applications to provide you with the advertising and promotional offers most relevant to your profile. Targeted advertising is an important aspect of our Services because it enables us to acquire the necessary funding to ensure their due fulfilment and preserve their status as free of charge.

On the website:

- navigation events and interaction with website content and services,

- cookie IDs, IP addresses and technical information about your browser and/or device (user agent),

- information that you give us voluntarily when you contact MARKETLUCK

4- WHY WE COLLECT DATA:

To provide services you have requested:

Legal basis: in the legitimate interests of the business: such data processing is absolutely necessary in order to be able to provide the service requested.

To perform analyses in order to understand how users interact with our product and services and thus continually improve them,

Legal basis: explicit consent. MARKETLUCK only processes or shares personal data collected via its applications for the purpose of analysis if you have given your consent via the consent pop-up included in the application.

To adapt advertising to our users’ preferences and interests and thus enable MARKETLUCK to go on providing services and products free of charge

Legal basis: explicit consent: MARKETLUCK only processes or shares personal data collected via its applications for the purpose of personalised advertising if you have given your consent via the consent pop-up included in the application.

For all data processing activities requiring the user’s consent, such consent may be withdrawn at any time on our application’s “settings” page.

However, should you withdraw such consent or refuse to give your consent, you will not or no longer be able to take part in any online competitions where participation is only free of charge because personalised advertising is displayed.

5- WHAT WE USE PERSONAL DATA FOR:

- To manage your account and our customer relationship:

We use your personal data to manage your player account and pursue our customer relationship.

This information also enables us to contact you in order to issue your prizes.

- Information, offers:

Depending on your choices, you may receive communications from us about special offers or invitations to take part in surveys concerning the development of our products and services. You can object to receiving such offers and newsletters or amend your choices at any time in the consent management section of your player account, accessible via the application menu, or by clicking on the unsubscribe link at the bottom of all our communications.

- Personalisation of Services

Subject to your choices, data collected may also be used to help us determine your player profile and suggest ways of personalising your player experience and offers that suit your particular interests, or to let you take advantage of special offers according to your playing habits. You can object to receiving the personalised communications and offers we send you at any time via the consent management section of your player account, accessible via the application menu

- Studies and statistics

We may wish to process your data for purposes of studies or statistics in order to improve our products and services and personalise our customer relationships. To this end, your data may be combined with other statistical or aggregated data from various third sources (in compliance with the French Data Protection Act).

6- WHO RECEIVES YOUR DATA: WHO MIGHT WE SHARE YOUR DATA WITH AND WHY?

Data collected from our Offers is sent exclusively to MARKETLUCK employees authorised to process it owing to their role within the company and with reference to the company's legitimate interests.

MARKETLUCK does not sell its users’ personal data; such data may however be shared with subcontracting parties (within the strict limits of performing the tasks entrusted to them) or, subject to your prior consent, with partner companies.

Such service-providers have only limited access to your personal data, in the context of performing the specific tasks assigned to them on our behalf, and are contractually obliged to protect it and use it solely for the purposes for which it has been disclosed to them, in compliance with the provisions of the applicable laws on personal data protection.

When you consent to the collection of your personal data for advertising or analytical purposes, we can share said data with the following types of recipient:

Advertising partners: who enable us to monetise the advertising inventory of our applications and provide users with free products and services.

Such partners generally collect the data with their own software development kits (SDK). A list of the partners implementing advertising SDKs via our application and the confidentiality policies regarding their services, which describe their practices and allow you to exercise your rights directly in this respect, is available below:

Adcolony
https://www.adcolony.com/privacy-policy

Applovin
https://www.applovin.com/privacy/

Facebook
https://www.facebook.com/policy.php

Google
https://policies.google.com/privacy

Ogury
https://ogury.com/privacy-policy/

Mopub
https://www.mopub.com/legal/privacy/

Adjoe
https://adjoe.io/privacy/

Unity
https://unity3d.com/legal/privacy-policy

Vungle
https://vungle.com/privacy/

TikTok
https://www.tiktok.com/legal/privacy-policy?lang=en

Palmup
https://palmup.io/privacy-policy

Data analysts: who provide us with tools and technologies to help us better understand how users interact with our services and thereby improve them.

These partners also usually collect the data with their own SDKs. A list of partners implementing analytics SDKs via our applications is available below:

Branch
https://branch.io/policies/

Facebook
https://www.facebook.com/policy.php

Appsflyer
https://www.appsflyer.com/privacy-policy/

Google
https://firebase.google.com/policies/analytics

Unity
https://unity3d.com/legal/privacy-policy

Push companies PushWoosh
https://www.pushwoosh.com/privacy-policy/

The company may need to pass on your data to bodies responsible for ensuring compliance with the law, if it considers this to be necessary or desirable in order to prevent or detect a breach of regulations or a case of fraud, including:

- to professional company advisers bound by a duty of confidentiality (lawyers, accountants, auditors),

-to judiciary or administrative authorities or local law enforcement agencies when the company is authorised to do so for legitimate reasons, or in cases where they are obliged by law to do so.

7- SHARING OF DATA:

We hereby inform you that MARKETLUCK may pass on some of your personal data and information to countries outside the European Union. Such transfers comply with the legal requirements and recommendations of the French Data Protection Authority (Commission Nationale Informatique et Libertés/CNIL) and can be subject to a specific legal framework intended to ensure that your personal data and information enjoys a high level of protection and security

8- WEBSITE USE

Like most websites, when you are browsing our site, information about your connection and device(s) is collected automatically to ensure that the site operates smoothly.

MARKETLUCK and its partners also use cookies and similar technologies to analyse how our users interact with our services and to administrate the website.

Cookies are small text files stored on your browser to enable the collation of unidentifiable information related to your website browsing.

You can control how cookies are used in your browser settings but this can affect the functionalities of some websites.

How we use cookies ?

A cookie is a small file which asks permission to be placed on your computer's hard drive. Once you agree, the file is added and the cookie helps analyse web traffic or lets you know when you visit a particular site.

Cookies allow web applications to respond to you as an individual. We use traffic log cookies to identify which pages are being used. This helps us analyse data about web page traffic and improve our website in order to tailor it to customer needs.

We only use this information for statistical analysis purposes and then the data is removed from the system. Overall, cookies help us provide you with a better website, by enabling us to monitor which pages you find used

What kind of cookies does MARKETLUCK use?

- Functional cookies

Role: These cookies are essential to the operation of our websites and applications. They enable you to browse our websites and applications and use their functionalities. If you choose to disable these cookies via your browser (here), it might alter your access to and/or use of our websites and applications. We recommend that you let them remain active in order to make full use of our services and your browsing on our websites and applications.

- Audience/analytics cookies:

Role: These cookies enable us to compile traffic statistics (e.g. number of visits/pages displayed/sections viewed, etc.) and understand visitor activity on our websites and applications, so that we can improve the functionality and user-friendliness of our websites and applications, thereby improving your browsing experience.

Advertising:

Role: These cookies are used to provide personalised advertising on our websites and applications or on other websites to suit your interests. These cookies are third-party cookies. Refusing these cookies will not prevent advertisements appearing on our websites and applications or on any other websites you visit. The advertisements you see, however, will no longer be personalised to suit your interests.

You can reset your mobile advertising identifier (IDFA on iOS or GAAID on Android) or activate the “limit ad tracking” option in your device settings if you wish to delete the connection between previously collected data and you or your device, and limit the collection of any additional data.

How can I manage cookies?

Cookies can only be stored on your device subject to your consent, which can be given and/or amended at any time. There are a number of ways to manage cookies.

NB - if you refuse to allow storage of the cookies needed for our websites and applications to operate properly, or if you delete those stored on your device, you will no longer be able to enjoy a certain number of functionalities that are needed for optimal browsing of our websites and applications (e.g., the cookie that enables us to see what kind of browser your device uses, for purposes of technical compatibility, its language and display settings or the country from which your device appears to be connecting to the internet). In such cases, we accept no liability for any consequences related to a poorly operating service resulting from our inability to store or read the cookies required to ensure the smooth operation of our websites and applications.

Choices concerning cookies that may be stored on your devices by MARKETLUCK can be amended at any time.

How can you exercise your right to choose via your internet browser?

You can configure your browser to enable cookies to be stored on your device or, on the contrary, to reject either all cookies or some, depending on who sent them. You can also configure your browser to ask you whether or not you want to accept a cookie whenever one might be placed on your device. To make or amend your choices with respect to cookies, go to the link for you particular browser:

If your device is also used by other people or if you have several browsers installed on the same device, we cannot be sure for certain that the services and advertisements sent to your device fully correspond to your use of the device and not that of another user.

How can you exercise your right to choose via your smartphone or tablet?

To disable cookies from an iOS device, you can opt for “Limit ad tracking”. For further information: Go to the page on disabling cookies in iOS.

To disable cookies from an Android device, you can opt for “Disable interest-based advertising”. For further information: Go to the page on disabling cookies in Android.

- Analytics and third-party cookies

MARKETLUCK uses Google Analytics to collect information concerning traffic to our website.

This service allows us to measure our website's performance and smooth operation and thereby offer you a better user experience.

For further information about data protection and confidentiality relative to these analytics services, you can find out about Google’s specific policies here:

https://policies.google.com/privacy?hl-fr and disable the collection of data by Google Analytics here:

https://tools.google.com/dlpage/gaoptout

- Social media and other communication tools:

Our website also offers communication tools that allow users to share content on social media. When you interact with this type of social media widget or “share button”, the social media companies concerned can gather information about you and/or your device and your connection; your interaction with its services are governed by the respective confidentiality policies of the companies providing these services.

For more information about the data protection and confidentiality practices of such companies, you can refer to their specific policies, as listed below:

- Facebook:

https://www.facebook.com/about/privacy/

- Links to other websites :

Our website may contain links to other websites of interest. However, once you have used these links to leave our site, you should note that we do not have any control over that other website.

Therefore, we cannot be responsible for the protection and privacy of any information which you provide whilst visiting such sites and such sites are not governed by this privacy statement.

You should exercise caution and look at the privacy statement applicable to the website in question.

9- LENGTH OF STORAGE

Personal data is stored in a form where identification is possible only for the time needed for the purposes for which said data is collected and processed.

Data required to manage your online account:

Length of storage: 6 years starting from the closure of your player account (legal requirement). Data required for business development: Length of storage: 1 year from date of last contact Data required for promotional operations: Length of storage: 5 years without prejudice to storage obligations or limitation periods. Cookies and trackers: Length of storage: 13 months

10- PERSONAL DATA SECURITY:

Throughout the whole period during which your personal data is stored, MARKETLUCK protects it by implementing the appropriate technical and organisational measures to ensure a level of security appropriate to the risk presented, preventing it from being damaged, erased or accessed by unauthorised third parties.

MARKETLUCK restricts access to the strict minimum.

11- YOUR RIGHTS REGARDING YOUR PERSOAL DATA:

What are your rights?

In compliance with the provisions of the applicable laws and regulations regarding personal data, you have the right to restrict and object to any processing of such data as well as rights of access, rectification, erasure and portability.

- Right of access: you have the right to ask the body responsible for processing your data to confirm whether or not your data has been processed.

- Right to rectify and object: you have the right to ask for any of your personal data that is incorrect or incomplete to be rectified as quickly as possible.

You have the right to object at any time to your personal data being processed, such as when used for purposes of business development.

If your request to object does not concern business development, the company can justify any refusal if:

- it has legitimate, imperative reasons for processing the data or because such data is required for the purposes of recognising, exercising or defending legal rights;

- you have given your consent - in such cases you must withdraw your consent rather than object;

- you have a contract with the organisation;

- there is a legal requirement that the company process the data;

- the data must be processed in order to safeguard the vital interests of the person concerned or any other private individual

- Right to restrict processing: you can ask for any processing of your data to be restricted if: - the accuracy of an item of personal data is contested; in such cases the body responsible for data processing must take the time to check the accuracy of the data, - the processing is unlawful and the person concerned does not wish the data to be erased but just to restrict its use, - the personal data is no longer needed for processing but is required for the purposes of recognising, exercising or defending the legal rights of the person concerned.

You can exercise your rights by writing to us at the following address: MARKETLUCK SAS sise 13-15 Immeuble Plainespace, 13 Avenue de la Métallurgie, 93210 SAINT DENIS, France, or via the internet by completing the form below:

Or you can send an email to the following address privacy@marketluck.com or write to us at the following address: data processing officer, MARKETLUCK SAS, 13-15 Immeuble Plainespace, 13 Avenue de la Métallurgie, 93210 SAINT DENIS, France

The request must be accompanied by proof of ID.

The company will reply within 1 month of your exercising your rights. In some cases, depending on the complexity of the request or the number of requests received, a reply may take an extra 2 months.

- Right to erase data:

You have the right to have your personal data erased as quickly as possible. However, the body responsible for processing such data may refuse to grant your request if processing is justified for: - statistical purposes, - exercise of the right to freedom of information and freedom of expression by opening the application’s consent preferences option at the bottom of the main menu.

Contact MARKETLUCK’s data protection officer at the following email address privacy@marketluck.com if you would like any data already collected by MARKETLUCK concerning you and/or your device to be permanently erased or anonymised.

You can also ask for your account to be deleted at any time by going to the same menu in the app. Your data will be deleted within a maximum of 15 days unless we have to keep it to meet legal requirements.

Right of portability:

When your personal data is processed in accordance with your consent or within the terms of a contract, you have the right to request its portability - this means that you have the right to be sent the data you gave us in a currently used, structured form that can be machine read, so that you can send it directly to another organisation in so far as this is technically possible. To do this, please email your request to “privacy@marketluck.com” - the subject line should be “Portability” and you should give the email address associated with your player account. If you do not provide your email address we will not be able to send you any data.

Right to lodge a complaint with the French Data protection Authority (CNIL)

You can lodge a complaint with the CNIL, if you feel that the way your data has been processed does not comply with the regulations.

12- CHILDREN’S PRIVACY 

Protecting the privacy of young children is extremely important. Thus Marketluck does not knowingly collect or solicit personal information from children under the age of 13 or knowingly allow them to register as players. Children under 13 should not send any information about themselves to us.

Should we learn that we have collected personal information from a child under age 13 without verification of parental consent, we will delete that information as fast as we can.

13 - CHANGES TO THE STATEMENT :

We may change this Statement from time to time. If we make significant changes in the way we treat your personal information, or to the Statement, we will provide you notice through the Services or by some other means, such as email. Your continued use of the Services after such notice constitutes your consent to the changes.

We encourage you to periodically review the Statement for the latest information on our privacy practices