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[legal.last_updated] : 24/10/2025

1. Data Controller

The data controller for personal data collected on Skill Game Platform is:

• Company name: Skill Game Platform
• Address: [Insert company address]
• Contact email: noreply@SkillGame.com

2. Personal Data Collected

2.1 Data Collected During Registration

Data	Purpose	Legal Basis	Retention
Email	Account creation, login, communication	Contract execution	Account lifetime + 3 years
Username	User identification, leaderboard	Contract execution	Account lifetime + 1 year
Password (hashed)	Authentication, security	Contract execution	Account lifetime
IP address	Security, fraud prevention	Legitimate interest	1 year (logs)

2.2 Banking and Payment Data

Data	Purpose	Legal Basis	Retention
IBAN	Withdrawal processing	Contract execution	10 years (legal obligation)
Payment card info	Credit purchases	Contract execution	Managed by Stripe (not stored by us)
Transaction history	Accounting, invoicing, support	Legal obligation	10 years

2.3 Game and Activity Data

Data	Purpose	Legal Basis	Retention
Scores and results	Leaderboard, ranking	Contract execution	Account lifetime + 1 year
Account balance	Game management, winnings	Contract execution	10 years
Game history	Statistics, support	Contract execution	3 years

2.4 Connection and Security Data

Data	Purpose	Legal Basis	Retention
Connection logs (IP, date, time)	Security, fraud prevention	Legitimate interest	1 year
Cookies and trackers	Session, preferences	Consent	See cookie policy

3. Purposes of Data Processing

Your personal data is processed for the following purposes:

• Account and service management: Registration, authentication, profile, technical support.
• Payment and financial transactions: Credit purchases, withdrawals, accounting.
• Games and competitions: Score saving, leaderboards, weekly redistribution.
• Communication: Transactional emails (confirmation, invoices, important notifications).
• Security: Fraud prevention, account protection, law compliance.
• Legal compliance: KYC (Know Your Customer), anti-money laundering, accounting.

4. Legal Bases for Processing

Data processing is based on:

• Contract execution: Essential data for providing the service (Article 6.1.b GDPR).
• Legal obligation: Financial, tax, anti-money laundering data (Article 6.1.c GDPR).
• Legitimate interest: Security, fraud prevention, service improvement (Article 6.1.f GDPR).
• Consent: Optional cookies (Article 6.1.a GDPR).

5. Data Recipients

Your data may be shared with trusted third parties:

Data	Purpose	Retention
Stripe	Secure payment processing	United States (EU-US Data Privacy Framework)
Hosting Provider	Data storage, application hosting	France/EU
SMTP Email Service	Sending emails (confirmations, notifications)	France/EU

We do not sell, rent, or share your data with third parties for commercial purposes.

We may disclose your data in case of legal obligation (court order, legal requisition).

6. International Data Transfers

Some service providers (such as Stripe) are located outside the European Union. In these cases:

• Transfers are secured by adequacy decisions (EU-US Data Privacy Framework).
• Providers comply with EU Standard Contractual Clauses (SCCs).
• All guarantees are in place to protect your data according to European standards.

7. Data Retention Period

Your data is retained for the duration necessary for the purposes for which it was collected:

Data	Retention
Active account	Duration of use of the platform
Inactive account (no login)	3 years of inactivity, then automatic deletion
Financial data (invoices, transactions)	10 years (legal obligation)
Connection and security logs	1 year
Game history and scores	3 years after account closure

After these periods, your data is permanently deleted or anonymized.

8. Your Rights (GDPR)

In accordance with the GDPR, you have the following rights:

8.1 Right to Access

You can obtain a copy of all your personal data we hold.

8.2 Right to Rectification

You can request correction of inaccurate, incomplete, or outdated data.

8.3 Right to Erasure ("Right to be Forgotten")

You can request deletion of your data, except for data we are required to keep by law (financial, tax).

8.4 Right to Restriction of Processing

You can request temporary suspension of processing of your data in certain situations.

8.5 Right to Data Portability

You can receive your data in a structured, commonly used format (JSON) and transmit it to another service.

8.6 Right to Object

You can object to processing based on legitimate interest (e.g., marketing).

8.7 Right to Withdraw Consent

You can withdraw your consent at any time for processing requiring consent (cookies).

How to Exercise Your Rights?

To exercise your rights, contact us:

• By email: noreply@SkillGame.com
• Subject: "GDPR - Exercise of Rights"
• Specify the right you wish to exercise (access, rectification, deletion, etc.)

We will respond within 1 month (extendable to 3 months for complex requests).

9. Data Security

We implement appropriate technical and organizational measures to protect your data:

• Password encryption: Passwords are hashed with bcrypt (irreversible).
• SSL/TLS connections: HTTPS for all exchanges.
• Secured database: Access restricted to authorized administrators only.
• Connection logs: Activity monitoring to detect suspicious behavior.
• Secure payment: Payments managed by Stripe (PCI-DSS certified).
• Security updates: Regular application and library updates.

Despite these measures, no online transmission method is 100% secure. We do everything possible to protect your data, but we cannot guarantee absolute security.

10. Cookies and Trackers

We use cookies to improve your experience:

Essential Cookies (required)

• Session: Maintain login.
• Security: CSRF protection.
• Language: Remember language preference.

Optional Cookies (requires consent)

• Analytics: Understand platform usage (if enabled).

You can manage cookie preferences in your browser or via our cookie management tool.

For more details, see our Cookie Policy.

11. Minors

Our platform is reserved for adults (18 years and older).

• We do not knowingly collect data from minors.
• If we discover that a minor has created an account, it will be immediately deleted.
• Parents can contact us if they suspect their child has created an account.

12. Changes to Privacy Policy

We may update this privacy policy to reflect legal or technical changes.

• Users will be informed by email of any major changes.
• The "Last updated" date at the top of the page indicates the version date.
• Continued use of the platform after changes constitutes acceptance of the new policy.

13. Contact and Complaints

For any questions about this privacy policy or your data:

• Email: noreply@SkillGame.com
• Subject: "Personal Data" or "GDPR"

File a complaint with a supervisory authority

If you believe your rights are not respected, you can file a complaint with:

14. Data Protection Officer (DPO)

For any question related to data protection:

• Contact email: noreply@SkillGame.com
• Subject: "DPO - Personal Data"