GAMEARLY’s role in processing your data
When does GAMEARLY act as a data controller?
GAMEARLY is responsible for the operational management of the Platform and Services. Any personal data processing necessary to enable the Platform to function or to generate User statistics is carried out by GAMEARLY as the data controller.
When does GAMEARLY act as a data processor?
When GAMEARLY carries out processing designed to provide a specific tool to the User, the User is the data controller, and GAMEARLY acts as the processor.
Which personal data processing activities does GAMEARLY carry out?
The tables below describe the data collected by GAMEARLY, the reason for this collection and its legal basis, the recipients of this data, and the retention period.
Longer archiving periods than those mentioned below may be implemented to allow GAMEARLY to fulfill its legal obligations.
2.1 Processing carried out as data controller
2.1.1. Processing concerning Users (players, Creators, Studios)
1. Management of Account creation and monitoring of Account usage
What data is processed?
Civil status (gender, last name, first name, date of birth), Postal address, Email, Username, Social ID (Meta, X, Telegram, Discord, TikTok, Twitch, YouTube, etc.) and related data (optional), Platform IDs (Steam, PlayStation, Xbox, Nintendo, etc.) and related data (optional), Number of XP, Type of player profile, Games played (optional), Electronic wallet address (optional), Language, Employer company (if creating a business account), Public or private profile, Date of account creation; Action history (missions, quests, progress, votes, transactions, purchases); Payment method (anonymized – only accessible to the payment provider).
On what legal basis is the data processed?
Contract (acceptance of the Terms and Conditions (CGUV) to open an Account), Consent (for optional data)
Who are the data recipients?
Support, Platform administrators
How long is the data kept?
Until the Account is closed by the User or their legal representative, or withdrawal of consent (for optional data). Or, in case of Account inactivity, 3 years after the last login
2. Listing of Creator Users on the Platform
What data is processed?
Last name, first name, username, Role, Education and degree, Professional experience, Software skills, Portfolio/Games on which the Creator has worked
On what legal basis is the data processed?
Contract (acceptance of the Terms and Conditions (CGUV) to open an Account)
Who are the data recipients?
Support, Platform administrators
How long is the data kept?
Until the Account is closed by the User or their legal representative,. Or, in case of Account inactivity, 3 years after the last login
3. Platform operation
What data is processed?
Connection and browsing data on the Platform (date and time of connection, IP address, location of the IP address, pages visited, browser type, browser language, event logs)
On what legal basis is the data processed?
Legitimate interest
Who are the data recipients?
Support, Platform administrators
How long is the data kept?
13 months
4. Monitoring User quests
What data is processed?
Social ID (Meta, X, Telegram, Discord, TikTok, Twitch, YouTube, etc.) and data associated with the User Account and quest completion
On what legal basis is the data processed?
Contract (acceptance of the CGUV to open an Account), Consent (for optional data)
Who are the data recipients?
Support, Platform administrators
How long is the data kept?
Until the Account is closed by the User or their legal representative. Or, in case of Account inactivity, 3 years after the last login.
5. Monitoring purchases and transactions
What data is processed?
Civil status (gender, last name, first name), Postal address, Email, Username, Transactions and purchases made, Payment method (anonymized – only accessible to the payment provider).
On what legal basis is the data processed?
Contract (acceptance of the CGUV)
Who are the data recipients?
Support, Platform administrators
How long is the data kept?
For the duration of the transaction, extended by the statutory limitation periods
6. Technical support – technical use of the Platform
What data is processed?
Last name, first name, Email / phone number, Nature of the issues encountered, Content of communications
On what legal basis is the data processed?
Contract
Who are the data recipients?
Support, Platform administrators
How long is the data kept?
For the time needed to handle the request
7. Combating IT fraud and traceability
What data is processed?
Logging of Account connection logs and actions performed from the Account
On what legal basis is the data processed?
Legitimate interest
Who are the data recipients?
IT Department
How long is the data kept?
1 year
8. Processing behaviors contrary to the law or the CGUV (fraud, inappropriate behavior on the forum, etc.)
What data is processed?
Data related to the Account, Inappropriate behavior (nature, date of occurrence, frequency), Date of formal notice to cease such behavior or date of notification to authorities
On what legal basis is the data processed?
Legitimate interest, Legal and regulatory obligation
Who are the data recipients?
Support, Platform administrators
How long is the data kept?
12 months or for the duration of the statutory limitation period
9. Collection of User opinions on the GAMEARLY Platform
What data is processed?
Content of the feedback and contextual elements if applicable, Last name, first name or username
On what legal basis is the data processed?
Consent
Who are the data recipients?
Sales, Marketing, Platform administrators
How long is the data kept?
Until consent is withdrawn. Feedback is anonymized after withdrawal of consent.
10. User Newsletter
What data is processed?
Email address, Newsletter opening, Time spent on the newsletter, Selection of one of the links in the newsletter
On what legal basis is the data processed?
Consent or legitimate interest
Who are the data recipients?
Sales, Marketing, Platform administrators
How long is the data kept?
Until withdrawal of consent or objection
11. Audience measurement
What data is processed?
IP address, Audience measurement cookies, Country, Connection time, Pages viewed
On what legal basis is the data processed?
Legitimate interest
Who are the data recipients?
Sales/Marketing Department, Partners
How long is the data kept?
Refer to the durations mentioned in the Cookies tab
12. Creation of statistics
What data is processed?
Age, Number of XP, Type of player profile, Games played, Language, Date of account creation; Action history (mission, quests, progress, votes, transactions, purchases), Pages viewed on the Platform, Platform IDs (Steam, PlayStation, Xbox, Nintendo, etc.) and related data (age, date of birth, country, platform ID, types of games, time played, wishlist, last purchase, social media platform, gender, nationality, country of origin, hardware used), Social ID (Meta, X, Telegram, Discord, TikTok, Twitch, YouTube, etc.) and related data (comments, quests completed)
On what legal basis is the data processed?
Legitimate interest
Who are the data recipients?
Sales/Marketing Department, Partners
How long is the data kept?
No time limit after anonymization of data
13. Content recommendation
What data is processed?
Age, Number of XP, Type of player profile, Games played (optional), Language, Date of account creation; Action history (missions, quests, progress, votes, transactions, purchases), Pages viewed on the Platform, Platform IDs (Steam, PlayStation, Xbox, Nintendo, etc.) and related data (age, date of birth, country, platform ID, game types, time played, wishlist, last purchase, social media platform, gender, nationality, country of origin, hardware used), Social ID (Meta, X, Telegram, Discord, TikTok, Twitch, YouTube, etc.) and related data (comments, completed quests), Creators: role (listing), education and degree, professional experience, software skills, portfolio/games the creator has worked on
On what legal basis is the data processed?
Consent
Who are the data recipients?
Sales/Marketing Department, Partners
How long is the data kept?
For the duration of the consent
14. KYC
What data is processed?
Last name, first name, date of birth, Postal address, Nationality, Digital wallet address
On what legal basis is the data processed?
Legal obligation
Who are the data recipients?
Sales Department, Payment provider, Token provide
How long is the data kept?
For the duration of the statutory limitation period
15. Age verification
What data is processed?
User’s date of birth
On what legal basis is the data processed?
Legal and regulatory obligation (prohibition of access for Users under 15)
Who are the data recipients?
Support, Platform administrators
How long is the data kept?
Until the Account is closed by the User or their legal representative. Or, in case of Account inactivity, 3 years after the last login.
16. Handling contact requests
What data is processed?
Last name, first name, Contact details (email, postal address, phone), Content of the request
On what legal basis is the data processed?
Consent
Who are the data recipients?
Sales Department, Marketing Department
How long is the data kept?
1 year
17. Handling requests to exercise rights under the GDPR
What data is processed?
Nature of the data concerned by the request, Request history, Legal basis for collection / method of obtaining consent, if applicable, Last name, first name, gender, Contact details (phone, email, etc.)
On what legal basis is the data processed?
Legal and regulatory obligation
Who are the data recipients?
Personal data representative, Platform administrators
How long is the data kept?
For the time required to handle the request
18. Handling requests to exercise rights under the GDPR
What data is processed?
Last name, first name, Postal address of Creators, Studios, Publishers, Position in the company, Company in question / company needs, Professional contact (email / phone), Appointment date
On what legal basis is the data processed?
Legitimate interest
Who are the data recipients?
Sales Department
How long is the data kept?
3 years from the last contact
19. Hosting
What data is processed?
All data hosted on the Platform
On what legal basis is the data processed?
Contract
Who are the data recipients?
Support, Platform administrators, Host provider
How long is the data kept?
Depending on the periods defined for each processing purpose
2.2 Processing carried out as a processor
1. Forums
What data is processed?
Username, Published content
On what legal basis is the data processed?
Contract (CGUV accepted by the User)
Who are the data recipients?
Users
How long is the data kept?
Until the published content is removed or the Account is closed (content is anonymized)
2. Provision of a private messaging service for Users
What data is processed?
User’s first and last name, Content of the message (and any attachments)
On what legal basis is the data processed?
Contract (CGUV accepted by the User)
Who are the data recipients?
Recipients of the message
How long is the data kept?
For the duration set by the User or until the Account is closed by the User or their legal representative. Or, in case of Account inactivity, 3 years after the last login.
3. Creation of statistics
What data is processed?
Age, Number of XP, Type of player profile, Games played (optional), Language, Date of account creation;, Action history (missions, quests, progress, votes, transactions, purchases), Pages viewed on the Platform, Platform IDs (Steam, PlayStation, Xbox, Nintendo, etc.) and related data (age, date of birth, country, platform ID, game types, time spent, wishlist, last purchase, social media platform, gender, nationality, country of origin, hardware used), Social ID (Meta, X, Telegram, Discord, TikTok, Twitch, YouTube, etc.) and related data (comments, completed quests), Creators: role (listing), education and degree, professional experience, software skills, Portfolio/Games the creator has worked on
On what legal basis is the data processed?
Contract with the Partner
Who are the data recipients?
Sales/Marketing Department, Partners
How long is the data kept?
For the duration of the contract
4. Eshop invoicing
What data is processed?
Last name, First name, Email, Postal address, Purchases made, Payment methods (anonymized), Data relating to the company, where applicable
On what legal basis is the data processed?
Contract
Who are the data recipients?
Accounting Department
How long is the data kept?
For the duration required to process payment
