privacy-policy - Focus Home Interactive

General Personal Data Protection Policy

Focus Home Interactive

INTRODUCTION

Focus Home Interactive (hereafter “We” or “our”) considers the protection of your personal information and data (hereafter “Data” or “your Data”) and the respect of your privacy to be of crucial importance. You will find in this General Personal Data Protection Policy all the relevant and transparent information regarding collection, usage, sharing, transfer and protection of your Data in relation to the use of our games, products and services.

This General Personal Data Protection Policy was last updated on July 6, 2020.

DATA CONTROLLER

FOCUS HOME INTERACTIVE, SA, registered in France under n° 399 856 277 at the PARIS Commercial Registry, headquartered at Parc de Flandre « Le Beauvaisis » Bâtiment 28, 11 rue Cambrai, 75019 PARIS, France, is the data controller of your Data as further described in this document.

KEY INFORMATION

We collect some of your Data through our video games and/or website, notably to allow you to:

Sign up to our newsletter, forum, and competitions;
Take part in testing our games;
Benefit from products and services you have requested;
Receive promotional and commercial offers if you have given your consent; and
Apply to our job and internship offers.

We mostly collect identification data and information regarding your use of our services (your email address, your name, your pseudonym, your password, your IP address). The categories of information that we collect in connection with your use of our games, products and services, as well as the related purposes and legal bases, are described in the table in section 3 of this General Personal Data Protection Policy.

You have right of access, rectification and deletion of your Data, the right to limit their processing, right to object to the processing, and right to portability. You can exercise these rights at any time by contacting our Data Protection Officer (DPO) at the following address personaldata@focus-home.com. If after having contacted us you feel your data protection rights have not been respected, you have the right to lodge a claim with the competent supervisory authority, such as the French Data Protection Authority (Commission Nationale de l’Informatique et des Libertés). When the processing of your data is based on your consent, you have the right to withdraw your consent at any time. For further information concerning your data protection rights, please read section 5 of this General Personal Data Protection Policy.

MINORS

Only minors of 15 years and older are allowed to subscribe to and use Focus Home Interactive products and services. We do not collect personal data of children aged under 15. If we realize that we have mistakenly collected data concerning a child aged under 15, we will delete all relevant data (see section 9 of this General Personal Data Protection Policy).

CONTACT

If you have any questions, concerns or claims regarding this General Personal Data Protection Policy or the processing of your Data, you can contact us:

by sending an email to our Data Protection Officer (DPO) at the following address personaldata@focus-home.com
by mail at the following address: Focus Home Interactive Parc de Flandre “Le Beauvaisis” Bâtiment 28, 11 rue Cambrai, 75019 PARIS, FRANCE

SUMMARY:

What Data is being collected?
How is your personal data collected?
For what purposes and on what basis does Focus Home Interactive process your Data?
With whom does Focus Home Interactive share your Data?
What are your rights and how can you exercise them?
How does Focus Home Interactive store your Data?
Transfer of personal data outside of the European Economic Area
How does Focus Home Interactive protect your Data?
Minors
Hyperlinks to other websites
Modification and update of the General Personal Data Protection Policy
Cookies and other tracking technologies

1. What Data is being collected?

We collect certain Data through our video games or website to offer you the best possible experience when using our products and services, and also for marketing purposes, but only with your prior consent. We mostly collect identification and usage/telemetry data.

When recruiting our staff, we only collect information relating to the professional profile that the candidate wishes to share with us.

The categories of information that we collect in connection to your use of our services, or our staff recruitment, as well as the corresponding purposes and legal bases, are described in the table in Section 3 of this General Personal Data Protection Policy.

Whether the data collected directly by Focus Home Interactive is mandatory or optional is indicated during collection, using an asterisk. If you refuse to give any of the mandatory information, you will not be able to benefit from all or part of the proposed services.

We only collect Data strictly necessary for our games, services related to our games or, as the case may be, strictly necessary for our staff recruitment procedure.

2. How is your personal Data collected?

Directly

- You sign up to the newsletter, to the forum, to the competitions or to the testing of our games (playtests); and
- You apply for one of the jobs proposed on our website.

(See Section 3 below)

Indirectly via:

- The use of cookies and other trackers (See Section 12 below);
- Third-party distributors and partners when you have expressly consented to giving your email address for commercial purposes, reception of newsletters and promotional materials;
- Our staff recruitment providers; and
- Your access to, or use, of some of our games and services available on social networks or other third-party platforms and websites.

(Collectively Third-Party Websites).

Please note that this General Personal Data Protection Policy does not apply to data processing implemented by Third-Party Websites, and that we do not control their respective data privacy practices. We recommend that you take careful note of the privacy policies available on each Third-Party Website, particularly the provisions relating to the sharing your Data.

Focus Home Interactive will process any Data received indirectly according to the conditions set out under this General Personal Data Protection Policy.

3. For what purposes and on what basis does Focus Home Interactive process your Data?

TYPE OF PROCESSING	CATEGORIES OF DATA	PURPOSE(S) OF PROCESSING	LEGAL BASIS FOR PROCESSING
Applications/staff recruitment	Identification data (full name, address, date and place of birth), professional experience and qualification data, and information provided in the Candidate’s CV.	To assess and evaluate the candidate’s suitability for the proposed job; and To manage the collection and processing of job applications.	Our legitimate interest to reinforce our staff and implement our recruitment policy.
Online services	Email address, login, pseudo, password.	To create your account; and To connect to your account once created. To provide the services you have signed up to according to the End User License Agreement that you have accepted; To provide and give access to features and extra content that you have requested (Mods, etc.); To manage your account and customer service; and To ensure the safety of your Data.	Necessary for the performance of the End User License Agreement.
Forum	Mandatory: email address, username/ pseudo, password; and Optional: Full name, age, website, address, description (freeform section where users can write whatever they like).	To sign up and interact with the Focus forum; and To ensure the proper functioning of the Focus forum.	Necessary to carry out the services relating to the Forum according to the terms and conditions you have accepted.
Playtests	Full name, age, identity photo, professional telephone, professional email, username/ pseudo.	To sign up to and take part in testing phases of video games published by Focus; and To ensure the correct execution of testing phases.	Necessary for the performance of the testing phase participation contract.
Focus Marketing	Full name, email address	To send you special offers, promotional and commercial materials concerning products and services similar to those offered by Focus	Your consent.*
Third-party marketing/Focus Home Interactive partners	Full name, email address.	To send you special offers, promotional and commercial materials concerning products and services from third-party partners.	Your consent.*
Playtests	Date of birth.	To allow us to check if you are 15 of over when participating in testing phases of games published by Focus.	To comply with our legal obligation not to process information concerning minors without consent or parental authorization.
Moderation	Username/ pseudo, full name.	To moderate user content; To allow us to verify the content in respect of the online services restrictions/code of conduct as set out under the End User License Agreement; To detect and prevent abuse or inappropriate use of the services provided by Focus; and To manage and/or remove any inappropriate, illicit or illegal content.	Necessary for the performance of the End User License Agreement and to comply with our legal obligations as publisher.
Requests from authorities and sharing Data as part of M&A operations	Identification data.	To comply with potential governmental requests, notably from judicial authorities, and to comply with any legal or judiciary request, if any; and To conduct / implement corporate operations such as restructuring, change of control, merger, acquisition, sale, dissolution, as the case may be.	To comply with our legal obligations to respond to requests from appropriate authorities, as the case may be; and Our legitimate interests to develop/extend the activities and business of Focus.
Statistical analysis and Security	Information regarding your use of our services.	To ensure and verify the efficiency and availability of the provided services; For internal purposes, to generate statistical data regarding the user of our services; For internal purposes, to carry out surveys and analyses allowing us to improve our services; and To ensure the security of Focus information systems.	Our legitimate interests are in particular to: Verify and correct issues relating to provided services, and regularly improve the services; Develop new features, new products and services; and Maintain an appropriate security level for Focus information systems.
Competitions	Personal data concerning participation in and organization of competitions and/or promotional operations: full name, email address, date of participation, answers to the competition and nature of the prices offered, and coordinates of the winners’ PayPal accounts.	To send you information and prizes as part of a competition or event.	Our legitimate interest: diversify, develop and expand the community of Focus players.
In-game technology tools (e.g. SDK)	Demographic data (language, state, city, GPS data) logs (connection details, login, IP address) technical specifications about the operating system, the device used in connection of our games, the mobile operator and the internet service provider; gaming data (Telemetry).	To enhance our game, your gaming experience and our online services; and To provide technical support.	Necessary for the performance of the End User License Agreement.
Cookies	Personal data obtained via cookie configuration (see section 12): in particular, a cookie’s unique identifier, IP address, terminal identifier, network types, country and language preferences, etc.	To customize your experience; To better understand your usage, your interests and preferences; To improve website, the application or the game performances; and To provide you with a technical support. For further information, please read section 12 of this General Personal Data Protection Policy.	Your consent given through the cookie management solution displayed when accessing the website or the application. For further information on consent mechanisms regarding cookies, please read section 12 of this Policy.

* You can withdraw your consent for reception of commercial/marketing communications by Focus Home Interactive or our partners at any time by clicking on the “Unsubscribe” link provided in each email, or by contacting us according to the procedure described in section 5 of this General Data Protection Policy.

4. With whom does Focus Home Interactive share your Data?

Communication of your Data with our providers and suppliers:

As a video game publisher, we can communicate or share some collected Data with our development studios, our IT providers, our recruitment agencies and providers, and our suppliers acting as subcontractors for technical and operational purposes to allow us to offer you quality games, to provide you with requested services, or to ensure effective recruitment.

We set up the contractual and organizational measures necessary so that the processing of your Data by these third-party providers is strictly limited to the purposes defined in this General Personal Data Protection Policy, and to ensure the confidentiality and security of your Data.

Communication of your Data with our commercial partners:

Subject to your prior consent obtained on the sign-up page of the website, we share your email address with trusted partners —whose identity will be specifically mentioned on the consent form—so they can send you promotional offers and other marketing materials. Please note that this General Personal Data Protection Policy does not apply to data processing by these trusted partners, acting as independent data controllers. We recommend that you take careful note of the privacy policies of these trusted partners.

5. What are your rights and how can you exercise them?

You have all of the following rights over the Data we collect and process:

Right to access your Data: you have the right to obtain (i) confirmation that your Data is or isn’t processed, (ii) when it has been processed, the right to obtain access to this Data, and (iii) a copy of any Data processed by Focus Home Interactive.

Right to request modification, update or rectification of your Data when you consider it is wrong, inaccurate or incomplete.

Right to request deletion of your Data for reasons provided by the applicable law and particularly when:

- The personal Data is no longer necessary to the purposes for which it was collected or processed;
- You withdraw your consent on which the processing was based, and there is no other legal basis for the processing;
- You object to the processing of the Data and there is no legitimate and compelling grounds for the processing;
- You consider your Data has been unlawfully processed; or
- Your Data must be deleted to comply with a legal obligation.

Right to limit the processing of your Data, for reasons set out under the applicable legislation, notably when:

- You challenge the accuracy of your Data;
- You consider the processing unlawful and you object to the deletion of your Data; or
- The Data is still necessary for establishment, exercise and defense of legal claims, whether Focus Home Interactive still needs the Data or not.

Right to object to the processing of your Data if we use your Data:

- For the performance of a task carried out for reasons of public interest;
- For our legitimate interests;
- For scientific or historical research purposes, or for statistical purposes; or
- For commercial and marketing purposes.

Right to withdraw consent at any time when the Data processing is based on your consent (note that this withdrawal does not affect the lawfulness of the processing based on consent before its withdrawal).
Right of Data portability: this right applies to Data you have provided to us when the Processing is automated and based on your consent, or carried out on the basis of the performance of a contract. You have the right to ask us, if it is technically feasible, to transfer your Data to a third-party or to provide them directly in an accessible and machine-readable manner.
Right to transfer instructions concerning storage and communication of your Data after your death.

Right to lodge a complaint with the competent supervisory authority, such as the French Data Protection Authority (Commission Nationale de l’Informatique et des Libertés) if you consider we do not respect our obligations with regard to your Data. You can lodge a claim or make an electronic request at any time by clicking on the following link: https://www.cnil.fr/fr/plaintes/internet.

To exercise your rights, you can send your request mentioning the relevant right(s) and the reasons, if necessary:

by sending an email to our Data Protection Officer (DPO) at the following address personaldata@focus-home.com; and/or
by mail at the following address: Focus Home Interactive Parc de Flandre “Le Beauvaisis” Bâtiment 28, 11 rue Cambrai, 75019 PARIS, FRANCE

We will assess and determine the admissibility of the request within one month after receipt. Assuming the request is admissible, we will provide the requested information or carry out the actions relevant to the rights cited in the aforementioned period.

If, in view of the complexity of the request or the number of simultaneous requests, the delay cannot be complied with, we will inform you before the expiry of this period that our response will be postponed for up to two months.

We will be entitled, if need be, not to respond to manifestly abusive requests (in particular due to their number, their repetitive or systematic nature).

6. How does Focus Home Interactive store your Data?

Your Data is stored only as long as necessary with regard to the purposes for which it was collected, and in accordance with the applicable law. Upon expiry of this period, we will delete your Data.

You will find below more information regarding the conservation periods applicable to certain specific purposes:

TYPES OF PROCESSING	CATEGORIES OF DATA	STORAGE PERIOD*
Applications/staff recruitment	Identification data (full name, address, date and place of birth), professional experience and qualification data, and information provided in the Candidate’s CV.	With your authorization, up to 2 years after our last contact.
Online services	Email address, login, pseudo, password.	During the usage period of our services and up to 3 years after our last contact.
Forum	Mandatory: email address, pseudo, password. Optional: Identification data (Full name, age, website, address, description) (freeform section where users can write whatever they like).	During the usage period of our services and up to 3 years after our last contact.
Playtests	Identification data (Full name, age, identity photo, pseudo), professional telephone, professional email. Date of birth.	During the development period of the tested game, and up to 3 years after our last contact. Until age of majority.
Focus Marketing	Full name, email address.	Up to 3 years after our last contact.
Third-party marketing/Focus Home Interactive partners	Full name, email address.	Up to 3 years after our last contact.
Moderation	Pseudo, full name.	Up to 3 years after our last contact, then your data will be automatically deleted if you do not reply when contacted. You can request the deletion of your data at any time.
Requests from authorities and sharing Data as part of M&A operations	Identification data.	As long as the information has operational interest concerning M&A operations, and as long as necessary in order to comply with authorities’ requests.
Statistical analysis and Security	Information regarding your use of our services.	5 years after deletion of your user account, retraction of your email address from our database, or deletion of your CV from our database.
Competitions	Personal data concerning participation in, and organization of competitions and/or promotional operations: full name, email address, date of participation, answers to the competition and nature of the prices offered, and coordinates of the winners’ Paypal accounts.	During the competition and up to 60 calendar days after the end of the competition.
In-game technology tools (e.g. SDK)	Demographic data (language, state, city, GPS data) logs (connection details, login, IP address) technical specifications about the operating system, the device used in connection of our games, the mobile operator and the internet service provider; gaming data (Telemetry).	These data will be kept for 2 years after their collection, and then we will pseudonymize and archive all the data only for statistical and administrative purposes.
Cookies	Personal data obtained via cookie configuration (see section 12): in particular, a cookie’s unique identifier, IP address, terminal identifier, terminal model, network types, country and language preferences, etc.	This data will be kept for 6 months and will then be automatically deleted.

*Focus Home Interactive will keep your Data for longer periods in intermediate storage, separate from the active database and with restricted access when justified in order to comply with our legal obligations and rights, notably in case of litigation or for administrative reasons in compliance with the applicable time limits, particularly in commercial, civil and fiscal matters.

7. Transfer of personal data outside of the European Economic Area

Focus Home Interactive may have to transfer some of your Data out of the European Economic Area (EEA) when necessary for technical or operational reasons, to allow us to offer quality games and requested services. These transfers are made in compliance with the applicable data protection regulation and data transfer mechanisms / safeguards recognized by the GDPR.

In particular, when the transfer of your Data cannot be handled on the basis of an adequacy decision by the European Commission recognizing an adequate level of protection, we will carry out other appropriate transfer and guarantee mechanisms to ensure the protection of your Data, such as with transfer agreements including standard contractual clauses as approved by the European Commission, or Privacy Shield for transfers carried out towards the United States.

8. How does Focus Home Interactive protect your Data?

We implement and maintain all appropriate technical and organizational measures to ensure the security, confidentiality and integrity of your Data, and to protect your Data from accidental or unlawful destruction, or accidental loss, damage, modification, disclosure or unauthorized access, as well as from other forms of unlawful processing.

For example, we maintain (among other security features) an authentication system to protect the access to your online accounts (login and password), hashing procedures for some of your Data, and access by employees and subcontractors of Focus Home Interactive restricted to an as-needed basis when providing our services, and subject to the respect of strict confidentiality obligations.

We regularly perform security tests and checks and may have to temporarily suspend our services if we suspect or detect a security breach.

If you have any concerns regarding the security of your Data, feel free to contact us at the following address: personaldata@focus-home.com.

9. Minors

Minors aged under 15 cannot subscribe directly to or use services offered by Focus Home Interactive.

Focus Home Interactive does not intentionally collect personal data from minors aged under 15 or under minimum equivalent age depending on the jurisdiction concerned. If we realize we have collected personal data regarding a minor within the meaning of the applicable data protection regulation, we will immediately delete any personal information regarding the minor in question.

10. Hyperlinks to other websites

The Site may contain links redirecting to other sites. As we have no control over these third-party websites, we cannot be held responsible for the processing and confidentiality of Data provided on websites other than our own.

Data and information transmitted via these links are under the responsibility of their editors. We therefore recommend you to be careful when browsing websites accessible via hyperlinks.

11. Modification and update to the General Personal Data Protection Policy

We periodically review this General Personal Data Protection Privacy to ensure it is compliant and up to date with applicable data protection regulation.

You will be notified in case of substantial changes to the policy (for example, if the modifications concern the categories of data to be processed or the purposes of processing), and we will send you a hypertext link to the updated General Personal Data Protection Policy within 30 days before publication. This information will be provided to you by email or will be made available via a pop-up window displayed when visiting our website.

12. Cookies and other tracking technologies

Cookies are small text files we place on your computer and terminals when you use our video games or visit our website. They are primarily used to run our games and our website, to make them work more effectively, and to get further information regarding your use of our services.

Focus Home Interactive uses cookies and other similar technologies (such as online storage) (collectively referred to as “cookies”) when necessary for authentication and security. We also wish to use optional cookies to offer you customized content and improve our services by analyzing how you use them. For further information as to the types of cookie and other trackers used by Focus Home Interactive, please read our cookie policy.

In any case, cookies will not be set for a period longer than 6 months, after which we will ask you again for your consent before setting cookies again.