VOXLERLET’S SING COMPANION Privacy Policy
October
2023
This
Privacy Policy applies to this App and its functionalities collectively
"the Services") of Voxler SAS, 8 Passage Brulon, 75 012 Paris ("VOXLER").
This
Privacy Policy shall explain how VOXLER collects and uses personal and
non-personal information when you use our services.
VOXLER
is serious about protecting users’ privacy and personal data. Our data
protection practices comply with the legal regulations of the respective
country of residence and the EU General Data Protection Regulation (GDPR). We
process your data only for the purposes described herein. We will only collect
the information we need to provide our services to you and to pursue our
legitimate interests. We shall only send you advertising or share your information with third parties if
legally allowed to do so or with your explicit consent . Furthermore, we
process your data if we are obliged to do so by law.
We
ensure that the law and this Privacy Policy are respected by us, our employees
and external service providers who work or otherwise carry out services for us.
For this we have taken appropriate technical and organizational measures, which
correspond to the state of the art (more information under Security of data).
If
you have further questions or comments regarding privacy or to assert your
legal rights, please contact VOXLER's Data
Protection Officer
Voxler SAS
DPO
Voxler SAS
8 Passage Brulon
75 012 Paris
E-Mail: dpo@voxler.com
PLEASE
READ THE FOLLOWING PRIVACY POLICY FOR INFORMATION REGARDING THE COLLECTION, USE
AND DISTRIBUTION OF PERSONAL DATA CAREFULLY WHEN YOU USE ANY ONLINE OR OFFLINE
GAME, PRODUCT, SERVICE OR WEBSITE FROM VOXLER OR REGISTER FOR ANY VOXLER
ACCOUNT.
What
data VOXLER collects depends on the Services you use. We collect personal as
well as non-personal data.
Personal
Data means any information relating to an identified or identifiable natural
person. Personal Data is one that identifies you directly or indirectly (also in
conjunction with other data) and that can be used to contact you online or
offline.
Examples
of personal data are: Name, address, phone number, email address, user ID, IP
address, location, payment information (credit card number, bank details).
The information
that you provide directly to us will be apparent from the context in which you
provide the data. In particular, we collect data as follows:
Our
Services do not collect any personal data themselves. In order to use our
services, you must connect the app to your Microsoft Azure Playfab account
("Playfab"). We do not receive any personal data from Playfab and are
not responsible for Playfab's processing of personal data. For more information
about Playfab, please refer to their privacy policy.
For
using the Services, you have to connect your Playfab to the app.
With
your consent, we will be happy to send you our newsletter. To do this, you must
register for our newsletter. More details on the content of the newsletter in
question are explained in the declaration of consent or on the registration
page.
You can
sign up for our free newsletter on our websites. For the registration to our
newsletter we use a double opt-in procedure for GDPR compliance provided that
GDPR applies to the country from which you are registering. After your
registration, we will send you a message to the specified e-mail address with a
link that you can click to confirm that you wish to receive the newsletter. If
you do not confirm your registration within 24 hours, your details will not be
used to send the newsletter and will be deleted after one week. In addition to
your e-mail address, we collect and save the time of the submission of your
consent. Only then can we document that you have voluntarily registered.
We also
point out that we evaluate your user behavior when sending the newsletter,
i.e., we can see if you open the newsletter or click on links contained in the
newsletter. For this evaluation, our newsletter includes a so-called "web
beacon". This is a pixel-sized file that we use to analyze the reach and
success of our newsletter and tailor it to your needs. For the evaluations, we
link the aforementioned data and the web beacons with your e-mail address and
an individual ID. Links contained in the newsletter also contain this ID. The
IDs are linked with further personal data from you including your name, Account
and user profile, country, and technical data such as browser and operating
system. By evaluating this data, we can assess the general use of the
newsletter and gain insights into which content and parts should be further
improved and developed according to user habits. This helps us to further
personalize the newsletter to your interests and preferences.
Your
data will only be used to send, evaluate, and personalize newsletters. We store
your data only as long as the subscription to the newsletter is active.
If
you're receiving our newsletter in the European Union or the European Economic
Area, Switzerland, or the UK, the legal basis for the related data processing
is Art. 6 para. 1 lit. a GDPR or the corresponding provision in the Swiss and
UK legislation, as the newsletter is only sent and evaluated with your consent.
You can revoke your consent and cancel the subscription at any time with effect
for the future. You will find a unsubscribe link in each newsletter.
You
can contact us by e-mail or through our contact form at any time and contact
our support team. In this case, the Personal Data transmitted by e-mail or with
your inquiry will be stored. The data is used exclusively for communication.
The
basis for the processing is our legitimate interest to respond to your request
as requested and is based on Art. 6 para. 1 lit. f GDPR.
The
data will be deleted as soon as it is no longer necessary for the purpose of
its collection.
You
can object to the storage of your data at any time. However, a proper response
to your inquiry can then no longer be guaranteed in individual cases.
Insofar
as we obtain the consent for processing of Personal Data, Art. 6 para. 1 lit. a
GDPR serves as lawful ground.
If the
processing of Personal Data is necessary for the performance of a contract to
which you are a party to, Art. 6 para. 1 lit. b GDPR serves
as lawful ground. This also applies to processing activities prior to entering
into a contract.
Insofar
as processing of Personal Data is required to fulfill a legal obligation we are
subject to, Art. 6 para. 1 lit. c GDPR serves as lawful ground.
Insofar
as processing of personal data is necessary for the performance of a task
carried out in a vital interest of the data subject or another natural person,
or in the public interest, Art. 6 para. 1 lit. d and lit. e GDPR serve as
lawful ground for processing.
If
processing is necessary to pursue our legitimate interests, and if your
interests, fundamental rights and freedoms do not prevail over our interest,
Art. 6 para. 1 lit. f GDPR serves as lawful ground for processing. Our
legitimate interests include, inter alia, the assertion, exercise or
defense of civil claims or the operation of our websites.
We will
process and store Personal Data no longer than necessary for the purposes for
which they have been collected. Subsequently, the Personal Data will be deleted
in accordance with the statutory provisions.
In
general, your Personal Data will be stored during the term of our contractual
relationships. However, in some cases, Personal Data may be stored for longer
due to EU regulations, laws or other regulations to which we are subject or for
as long as the retention of Personal Data is required due to other legal
reasons (e.g. in accordance with Art. 17 para. 3 GDPR). This may include
keeping your Personal Data after you have deactivated your account for the
necessary period for us to pursue legitimate business interests, comply with
(and demonstrate compliance with) legal obligations, resolve disputes or
enforce our agreements. If there are legitimate reasons opposing a deletion,
for instance statutory retention or storage periods, processing of these data
will be limited. In such case the data will be erased as soon as the reason for
further storage ceases to exist, for example if the statutory retention period
expires.
Is the
right to process Personal Data based on your consent in accordance with Art. 6
para. 1 lit. a GDPR the data will be deleted as soon as the purpose of the
storage is canceled or if you revoke your consent. A revocation is possible at
any time. The revocation of your consent does not affect the lawfulness of the
processing carried out on the basis of the consent until the revocation.
Please
contact our Data Protection Officer
for any inquiries. For more information please see Your legal rights.
VOXLER does not
transfer any Personal Data to third parties.
VOXLER may
also disclose Personal Data to law enforcement
or the relevant civil authorities to enforce legal rights and to comply
with the law, or to comply with a decision by a government or other competent
authority, or if we have reason to believe that disclosure is required to
respond to potential or actual violations or interference with our rights, property,
reputation, business operations, users or others who may be harmed, or if we
believe disclosures are required to protect our rights or us against fraud, or
to comply with any lawsuit, court order or legal process served.
In the
context of corporate transactions (acquisition, sale, restructuring of
companies or company shares), third parties may gain access to your Personal
Data. Disclosure for this purpose serves our legitimate interest pursuant to
Art. 6 para. 1 lit. f GDPR.
If you
are located in the European Economic Area or Switzerland, we comply with
applicable laws to provide an adequate level of data protection for the
transfer of your Personal Data to the USA and to other countries outside of the
European Economic Area (“Third Countries”). Please note that some Third
Countries, including the USA, do not guarantee an adequate level of data
protection. Transferring data to these Third Countries may therefore involve
additional risks for your privacy rights. For example, the enforcement of your
rights can be more difficult in these Third Countries.
However,
we use our best efforts to ensure that an international data transfer to Third
Countries is governed by an adequate data transfer mechanism based on a risk
assessment regarding the transfer. We rely on one or more of the following
mechanisms: EU Standard Contractual Clauses with a data recipient outside the
European Economic Area, and/or verification that the European Commission has
adopted an adequacy decision in accordance with Art. 45 GDPR for the respective
Third Country.
Certain Services are provided to you in
partnership with third party(s) and may require you to disclose Personal Data
in order to register for and access the Services. Such Services shall identify
the third party partners during the registration. If you choose to register for
such Services your Personal Data will be transferred to such third parties and
will be subject to the privacy policy and practices of such third parties. We
are not responsible for the privacy practices and policies of such third
parties and, therefore, you should review the privacy practices and policies of
such third parties prior to providing your personally identifiable information
in connection with such products and/or services.
For
further information about the EU Standards Contractual Clauses, please contact our
Data Protection Officer by email to dpo@plaion.com.
Protecting
the privacy of children is particularly important to us. VOXLER understands
that parents, guardians or other adults often use our family services,
including for use by minors. If a minor under the age of 16 (or below the
minimum age in the Member State concerned, which can be lower) submits Personal
Data to VOXLER and we learn that such Personal Data contains information of a
child below 16 (or below the minimum age in the area, which could be lower) and
there is no effective consent, we will delete the data as soon as possible. It
is our policy to comply with any applicable law protecting minors.
The
consent of children under the age of 16 is only lawful if the parents have
given their consent. Each member state of the EU can reduce the age to a
maximum of 13.
VOXLER,
taking into account the available technology, makes efforts to make sure that
the parents have given their consent to children. Nevertheless, we would like
to make parents aware that age verifications can be technically bypassed.
Please do not leave your children unattended on the Internet and explain their
importance to the proper handling of their data.
We
remind you that in various technical areas we work with external partners who
also offer websites and services accessible from our Services. The fact that we
link to a website is not an endorsement, authorization or representation of our
affiliation with that third party. If you click on a link to a third party
site, including on an advertisement, you will leave the VOXLER site and go to
the site you selected. As we cannot control the activities of third parties, we
cannot accept responsibility for any use of your personal information by such
third parties, and we cannot guarantee that they will adhere to the same
privacy and security practices as VOXLER. These third party websites and
services should have their own privacy policies. We assume no responsibility or
liability for such declarations or activities that take place at other sites.
We encourage you to review the privacy policies of any other service provider
from whom you request services. If you visit a third party website you should
consult that site's privacy policy before providing any personal information.
You
can revoke a given consent at any time. To ensure the security and
integrity of your Personal Data, we may ask you for additional information in
justified cases to verify that you are the owner of that data. The revocation
of consent does not affect the legality of the processing carried out on the
basis of the consent until the revocation.
You
can also request information from us at any time as to which Personal Data we
process from you (Right of Access,
Art. 15 GDPR). Insofar as the data concerning you is incorrect or incomplete,
you have a Right of Rectification
(Art. 16 GDPR). In certain cases, you have the right to request a restriction of processing. Details can
be found in Art. 18 para. 1 GDPR.
You
can demand that the Personal Data concerning you shall be deleted immediately (Right to Erasure, Art. 17 GDPR). In
particular, we are required to immediately erase this information if the data
is no longer necessary for the purposes for which it was collected or if you
revoke your consent. Further deletion obligations can be found in Art. 17 para.
1 GDPR.
Please
note, however, that statutory provisions provide for a retention period and we
are allowed to store data for the settlement of disputes, for the enforcement
of our Terms of Use and due to technical and legal reasons (e.g. backup files).
This data may only be deleted after periods of time specified by law.
If
you have the right to rectify, delete or restrict the processing by us, we are
obliged to notify all recipients to whom your personal data have been disclosed
of this correction or deletion of the data or restriction of processing, unless
this proves to be impossible or involves a disproportionate effort (Notification Obligation, Art. 19 GDPR).
You also have the right at any time, for reasons arising from your particular
situation, to prevent and object the
processing of your Personal Data, pursuant to Art. 6 para. 1 lit. e or f GDPR.
You
also have the right to receive personally identifiable information you provide
to us in a structured, common and machine-readable format. You also have the
right to transfer this data to another person without hindrance (Right to Data Portability, Art. 20 GDPR).
Please
note that in we may reasonably ask you for additional information to verify
that you are the owner of this data. This is for the security and integrity of
your data.
Without
prejudice to any other administrative or judicial remedy, you have the right to
file a complaint to a supervisory authority, in particular in the Member State
of residence, place of work or place of alleged infringement, if you believe
that the processing of the personal data concerning you is violates the GDPR.
Please
direct your data protection request to the Data
Protection Officer of VOXLER.
We
are regulated under the California Consumer Privacy Act (“CCPA”), which applies to California residents.
Under the CCPA, California residents have several
important rights:
- Right to Know: You can ask us what Personal
Data we hold about you and request a copy. This includes:
·
The
type and specific pieces of personal data we have collected;
·
The
types of sources we collect the data from;
·
The
purpose for collecting your Personal Data;
·
The
third parties we share that data with.
-
Right
to Delete: You can request that we erase your Personal Data. There are some
exceptions to this right, if we:
·
Need
to complete the transaction for which the Personal Data was collected or if
there is an ongoing business relationship or contract with you;
·
Detect
security incidents and protect against malicious, deceptive, fraudulent, or
illegal activity;
·
Need
to identify and repair errors affecting Service functionality;
·
Exercise
free speech or ensure another consumer can exercise (or another lawful right);
·
Need
to comply with the California Electronic Communications Privacy Act
·
Engage
in research in the public interest;
·
Enable
solely internal uses that are in line with your expectations for using your Personal
Data;
·
Need
to comply with a legal obligation;
·
Otherwise
use your Personal Data internally, in a way that’s compatible with the reason
we collected it in the first place.
-
Sale
of your Personal Data: We don’t sell any of your Personal Data for any
purposes.
-
Other
Rights: California residents also have the right to request information about
our disclosure of Personal Data to third parties for direct marketing purposes
during the calendar year before your request. This request is free and may be
made only once a year.
We
won’t discriminate against you for exercising any of the rights listed above.
If
you would like to exercise any of those rights, please contact our Data
Protection Officer and email us at dpo@Voxler.com. To ensure the security and
integrity of your data, we may ask you for additional information in justified
cases to verify that you are the owner of that data.
We
are regulated under the Lei Geral de Proteção de Dados (“LGPD”), which applies to Brazilian residents.
Under
the LGPD, Brazilian residents have several important rights:
-
Know
when we use your Personal Data
-
Access
your personal data, correct any errors, or delete your Personal Data
-
Anonymize,
block, or delete data that we don’t need or are not processing in compliance
with the LGPD
-
Request
we transfer your Personal Data to another provider
-
Be
informed about who we share your Personal Data with
-
Be
informed about your ability to deny consent and any consequences
-
To
revoke your consent
These
rights apply to any personal data collected or processed in Brazil, as well as
any Personal Data processed for the purpose of providing goods or services in
Brazil.
If
you would like to exercise any of those rights, contact our Data Protection
Officer an email us at dpo@Voxler.com. To ensure the security and integrity of
your Personal Data, we may ask you for additional information in justified
cases to verify that you are the owner of that data.
VOXLER
reserves the right to modify
and update this Privacy Policy at any time in accordance with applicable
privacy laws. If we change our Privacy Policy, we will post those changes to
this Privacy Policy, the website or other places so that you are aware of what
information we collect, how we use it, and under what circumstances, if any, we
disclose it. If we make material or significant changes to this Privacy Policy,
we will notify you by email or by a notice on the applicable websites or during
log in. Please visit this page frequently.
If
you have any questions, concerns or remarks about data privacy, please contact our
Data Protection Officer by email to dpo@plaion.com.