개인정보 처리방침

1.1. We are Studio Pango SAS  (“Studio Pango“). You can reach Studio Pango' Privacy Officer:

Julien AKITA

6 Bis Impasse des Robiniers

69290 Craponne, FRANCE

pango@studio-pango.com

1.2. Studio Pango is a “data controller” as defined by the applicable data privacy regulations. This means that we are responsible for deciding how to store and use your personal data.

1.3. This policy notifies you how we process personal data that we collect from you or that you give us.

1.4. This policy pertains to data collected about you when you use our website and our mobile applications (called “website” and “mobile apps” hereinafter).

1.5. Studio Pango takes many precautions to protect the online privacy of children. Whenever we refer to "children" in this Privacy Policy, we mean children under the age of 13. Please help us in protecting children's privacy by instructing them to never provide any personal information (full name, email address, home address, phone number, etc.) without your permission.

1.5.1. Studio Pango follows the principles of the Children's Online Privacy Protection Act ("COPPA"), a U.S. law designed to protect the online privacy of children, in our online services and Apps that are directed to children. If you would like to learn more about COPPA, you can refer to the "Children's Privacy" section of the Federal Trade Commission's website.

1.5.2. Studio Pango follows the principles of the General Data Protection Regulation ("GDPR"), an European law designed to protect the online privacy of children, in our online services and Apps that are directed to children. Law No. 78-17 of January 6, 1978, as amended, relating to information technology, files and freedoms, and Regulation (EU) 2016/679 of the European Parliament and of the Council of April 27, 2016 (hereinafter the "RGPD").

1.6. If you don’t agree with this Privacy Policy, you should not use the “website” and “mobile apps”.

2.1. We collect the following data in connection with your use of our website and the mobile apps:

2.1.1. Details about contact with our support team and the data you provide in this context (e.g. contact data);

2.1.2. Details about your visits to our website and use of the mobile apps (e.g. location data, weblogs, other communication data and resources you use);

2.1.3. Information about your use of our information and communications systems;

2.1.4. Browser information and online identifiers (such as your browser types, your browser version, your host operating system, your browser language and your IP address);

2.1.5. Information about your visit to the websites and use of the mobile apps (such as URLs, clickstream to, on, and away from our website, page reaction times, download errors, duration of visits to particular pages, information about interaction between pages (such as scrolling, clicks, and mouse movements) and methods of leaving the page);

2.1.6. Aggregated information (such as aggregated data traffic information that is collected during your visit to the websites and use of the mobile apps).

2.1.7. Additionally, we may use cookies and web beacons to help deliver and analyze our services (e.g., counting the number of times a page or advert has been viewed). We also use cookies to personalize content and ads.

2.2. If you have consented to receiving a newsletter:

2.2.1. The email address you provided.

2.3. We do not knowingly collect personal information of children (i.e. individuals under 18 years old) in connection with visits to our website and use of our mobile apps. If it is brought to our attention that we have received data from individuals under 18 years old, we will make appropriate efforts to remove it from our records.

3.1. We process the data listed in number 2.1 for the following purposes:

3.1.1. To ensure a smooth connection to the website and running of the mobile apps;

3.1.2. To ensure comfortable use of our website and the mobile apps;

3.1.3. To evaluate system security and stability;

3.1.4. To process your support requests;

3.1.5. For other administrative purposes.

3.2. We only process the data listed in number 2.2 for marketing purposes to provide you with information about our products and services in a newsletter, if you have given us your permission to do this. You have the right to revoke consent to the use of your data for marketing purposes at any time with effect for the future. Please contact pango(at)studio-pango.com by email to do this.

4.1. The legal basis for the processing described in numbers 3.1 arises from our legitimate business interest pursuant to Art. 6 (1), sentence 1, point (f) of the GDPR.

4.2. The legal basis for the processing described in numbers 3.2 arises from your consent pursuant to Art. 6 (1), sentence 1, point (a) of the GDPR.

5.1. Subject to explicit regulations otherwise in this policy, your data is only transmitted to third parties if

5.1.1. We have received your explicit consent to this pursuant to Art. 6 (1), sentence 1, point (a) of the GDPR;

5.1.2. The transmission is necessary pursuant to Art. 6 (1), sentence 1, point (f) of the GDPR to establish, exercise, or defend legal claims and there is no reason to assume that you have a prevailing protected interest in non-transmission of your data;

5.1.3. If a statutory obligation exists in regard to the transmission pursuant to Art. 6 (1), sentence 1, point (c) of the GDPR; and

5.1.4. This is legally permissible and is required to process contractual relationships with you pursuant to Art. 6 (1), sentence 1, point (b) of the GDPR GDPR.

5.2. If you have consented to receive newsletters, your email address will be transmitted to service providers of Studio Pango that support us technically in sending our newsletters. Such transmission takes place solely within the framework of a contract data processing agreement under which we have authority to issue instructions in regard to the affected data. If the service provider’s registered office is outside the EU or the EEA, we ensure a level of data privacy that complies with applicable data privacy regulations.

5.3. If you click on an affiliate link on our website or in our mobile apps, the relevant vendor of the shop only receives from us the information that the click came from our website or our mobile app.

The website and our mobile apps may contain links to third-party websites. If you follow a link to such a website, please note that your use of such a website is subject to the data privacy conditions of said website and that we assume no responsibility or liability for your use of such a website. Please read the data privacy conditions of this third-party website before transmitting personal data to such a website.

7.1. We only store your personal data as long as necessary to fulfill the purposes for which we collected it, including to fulfill legal, accounting, or reporting obligations.

7.2. In some cases, we may anonymize your personal data so that it can no longer be linked to you; in such a case, we may use this data without further notifying you.

We use cookies on our website and our mobile apps. Cookies are small files automatically created by your browser and stored on your end device (laptop, tablet, smartphone, etc.) when you visit our website or use our mobile apps. Cookies do not harm your end device and do not contain viruses, Trojan horses or other malware. The cookie stores information created in connection with the specific end device used. However, this does not mean that we obtain direct knowledge of your identity. One purpose of cookies is help us make using our offer more enjoyable for you. For example, we may use so-called session cookies to detect that you have already visited individual pages on our website or used our mobile apps. These are automatically deleted after your leave our website or our mobile apps. We also use temporary cookies to optimize user friendliness. They are stored on your end device for a specific fixed amount of time. If you visit our website or use our mobile apps to access our services again, it is automatically recognized that you have already been there and what inputs and settings you provided so that you need not enter these again. We also use cookies to record statistics about the use of our website or mobile apps and analyze them in order to optimize our offer for you (see number 3). If you visit our website or our mobile apps again, these cookies allow us to automatically detect that you have already been there. These cookies are always automatically deleted after a defined time. The data processed by cookies is needed for the stated purposes to protect our legitimate interests as well as those of third parties pursuant to Art. 6 (1), sentence 1, point (f) of the GDPR. Most browsers automatically accept cookies. However, you can configure your browser so that no cookies are stored on your computer or so that a notice always appears before a new cookie is created. However, wholesale deactivation of cookies may lead to you not being able to use all the functions of our website or our mobile apps.

9.1. Tracking tools

The tracking measures listed below and used by us are implemented based on Art. 6 (1), sentence 1, point (f) of the GDPR. The tracking measures used are intended to ensure needs-based design and continuous optimization of our website or our mobile apps. We also use tracking measures to record statistics about the use of our website or mobile apps and analyze them in order to optimize our offer for you. These interests are legitimate as defined by the regulation cited above. The particular data processing aims and data categories can be found in the corresponding tracking tools.

Google Analytics  (policies.google.com/privacy )

OVH (https://www.ovh.ie/personal-data-protection/privacy_policy.xml)

Unity (unity3d.com/legal/privacy-policy)

SendinBlue (https://fr.sendinblue.com/legal/privacypolicy/)

10.1. We may include links to third parties from our website or services. Studio Pango isn’t responsible for these companies and including a link to them doesn’t mean that Studio Pango endorses them. Our privacy policy applies only to our website, so if you click on a link to another website, you should read their privacy policy.

10.2. Your use of Studio Pango’s sites and services may also be subject to the terms and conditions and privacy policies of other services that Studio Pango doesn’t control. This includes mobile application stores, mobile software platforms, online social media sites, and payment processors.

You have the right:

11.1. Under Art. 15 GDPR, to request information about your personal data that we process. In particular, you can request information about the purposes of the processing, the categories of personal data concerned, the categories of recipients to whom the personal data has been or will be disclosed, the envisaged period for which it will be stored, the existence of a right to rectification, erasure, restriction of processing, or objection, the existence of a right to lodge a complaint, the source of your information if it was not collected from us, and the existence of automated decision-making, including profiling, and, if applicable, meaningful information about the details;

11.2. Under Art. 16 of the GDPR, to request the rectification of inaccurate or completion of the personal data stored by us without undue delay;

11.3. Under Art. 17 of the GDPR, to request erasure of personal data stored by us unless the processing is necessary to exercise the right to free expression and information, to comply with a legal obligation, for reasons of public interest, or to establish, exercise, or defend legal claims;

11.4. Under Art. 18 of the GDPR, to request the restriction of processing of your personal data if you contest the accuracy of the data, if the processing is unlawful but you oppose erasure, and we no longer need the data, but you need it to establish, exercise, or defend legal claims or you have objected to processing under Art. 21 of the GDPR;

11.5. Under Art. 20 of the GDPR, to receive your personal data that you have provided to us in a structured, commonly used, and machine-readable format or to request transmission to another controller;

11.6. Under Art. 7 (3) of the GDPR, to revoke at any time the consent you granted to us. The consequence of this is that we may in future no longer continue the data processing based on this consent and

11.7. Under Art. 77 GDPR, to lodge a complaint with a supervisory authority. In general, you can do this with the supervisory authority of your habitual residence or place of work or our corporate headquarters.

Insofar as your personal data is processed based on legitimate interests pursuant to Art. 6 (1), sentence 1, point (f) of the GDPR, you have the right under Art. 21 of the GDPR to object to the processing of your personal data if there are grounds that arise from your particular situation or the objection is to direct marketing. In the latter case, you have a general right to object that we will implement without requiring any particular situation. If you wish to make use of your right to revoke consent or to object, an email to pango(at)studio-pango.com suffices.

We make use of appropriate technical and organizational security measures to protect your data against accidental or intentional manipulation, full or partial loss or destruction, and unauthorized access by third parties. Our security measures are continuously being improved as technology develops.

This data privacy policy is currently valid as of December 2018. Because of the continuing development of our website, our mobile apps, and offers beyond these or because of changing statutory or regulatory standards, it may become necessary to amend this data privacy policy. You can access and print out the current up-to-date data privacy policy at any time on the website under https://www.studio-pango.com/policy .