1. AIM OF THE PRIVACY POLICY

The Privacy Policy represents an ongoing concern for Two Up and companies affiliated to it (mother company, subsidiaries, etc.) (hereinafter referred to as Two Up) in ensuring the protection of the private lives of users of the services described hereinafter in view of current regulations and in particular, Law 78-17 of January 6, 1978 relating to information technology, files and freedom and and with the EU's General Data Protection Regulation (GDPR) (EU) 2016/679. The current Privacy Policy is an integral part of the Terms and Conditions of Use governing the games and software applications provided by Two Up, in particular via third-party social network platforms (hereinafter referred to as “Platforms”), including all content, all services and all features accessed via these games and software applications (hereinafter referred to collectively as “Services”). In particular, the current Privacy Policy aims to inform you of the general policy implemented by Two Up in terms of protecting personal data collected and processed as a result of using the Services governed by the aforementioned Terms and Conditions of Use. By accessing and/or using the Services, you explicitly accept the terms of this Privacy Policy and, as a consequence, agree to the gathering, retaining, using and divulging of your personal data, as described herein. You are hereby advised that the Privacy Policy can be modified by Two Up at any time. With this in mind, by continuing to use and/or access the Services after the last-modified date of any changes, you will be deemed to have accepted these changes as modified. You are therefore invited to regularly consult the Privacy Policy to ensure you are up-to-date with any potential changes.

  1. DATA COLLECTION

2.1 Data collected by Two Up via the Platforms

The data collected and processed are willingly supplied by you to Two Up through the Platforms by agreeing to access and use the Services from these Platforms. At a minimum, such data will include your name, profile photo, sex, your network(s), username, the user ID numbers of your friends and/or people belonging to your network(s) and other information supplied by you to all users of the Platforms. If applicable, Two Up is also likely to collect, still via the Platforms, any additional data you may agree to supply to it (e.g., your email address). As all personal data are supplied directly to Two Up by the Platforms, it is deemed that you have read and agreed to the Platforms’ terms and conditions of use and their privacy policy. Two Up shall not be held liable for the way in which Platforms act in terms of collecting, storing and processing your personal data. In addition, you are responsible for the privacy settings of your accounts on the Platforms in such a way that Two Up cannot be held liable in this regard.

2.2 Data collected by Two Up directly

Through provision of its Services, Two Up may also collect data from you directly. As such, by using certain features within the Services which require online payment, you agree that your bank details, email address and/or your telephone number may be collected in compliance with current regulations in force. Within the context of using its Services and/or related official spaces (dedicated official spaces on the Platforms, support website, etc.), Two Up may also invite you to participate in promotional events (contests, free sweepstakes, etc.). Participation in these promotional events implies your full and complete agreement to the collection, storage and processing of any personal data you supply. If applicable, and within the context of using the Services, the number of points you collect may be retained in order to determine your rank/level with the particular purpose of defining player rankings. By using the Services, you agree, in particular, that your score, your rank/level, your ID and your photo be listed in the overall player ranking, which all users of the Services will be able to view. Furthermore, when you contact Two Up directly via its support service, the latter may collect and store your contact data (in particular your name, mailing address and email address) and, where applicable, your user ID number for the Platforms from where you access and use the Services, as well as some information relating to your use of the Services that you will provide to Two Up. Finally, Two Up may need to collect aggregate data in order to be able to provide an optimized level of Services. This may include data such as your IP address, browser type, browser language, number of clicks, pages viewed and also, more generally, browsing and connection data.

  1. PURPOSES OF COLLECTING AND PROCESSING YOUR DATA

Two Up collects, stores and processes your personal data with the aim of enabling you to access and use its Services effectively. Data collected from the Platforms and/or directly from you enable in particular the better administration and improvement of the Services, communication between users of the Services, the supply of technical support and efficient responses to user requests, proper application of the Terms and Conditions of Use, which govern Two Up Services, communication about new and current Services along with promotional offers, the analysis of user traffic trends and the collection of statistical data or even the targeting of advertising content that may appear on our Services. When you receive promotional communications on behalf of Two Up, you will have the opportunity to put and end to them by following the unsubscribe instructions contained in the communication itself.

  1. RECIPIENTS OF YOUR DATA

Your data will not be provided to third parties, except in the following cases:

We would like to draw your attention in particular to the fact that by using certain Two Up Services via the Platforms, other users of these Services will be able to view your user profile for these Platforms. This profile may enable other users to obtain information associated with this profile made public by you. Two Up cannot be held liable in this regard. The settings for information associated with your profile are your responsibility. Two Up does not share your personal data with third-party advertisers for marketing purposes unless you have provided prior consent for it. Nevertheless, it should be noted that advertisers may obtain personal data which relates to you from your user profile on the Platforms or from other public sources. In the same way, Two Up shall not be held responsible in this regard. On the other hand, Two Up may use and share certain non-personal technical or aggregate data relating to the browsing of Services users with certain third parties. Please refer to article 7 for a few examples of browsing data. Two Up may allow advertisers to collect this type of technical or aggregate data using certain technology such as cookies and to do so in order to be able to offer targeted advertising within the more general context of personalizing your user experience. The gathering, processing and divulging of such anonymous data shall not be subject to the restrictions cited in the current privacy policy.