Privacy Policy
1. Who we are
This Privacy Policy explains how personal data is handled in the mobile game Poker With Your Friends (the “Game”). The data controller is:
Hadrien De Ryck, sole proprietorship (entreprise individuelle), trading as TestinGames
SIREN 940 152 374
6 rue des Tastes, 33460 Soussans, France
Contact: info@testingames.fr – testingames.fr/contact
2. Data we process
| Data | Where it comes from | What it is used for |
|---|---|---|
| Nickname | You choose it in the Game. | Shown to the other players in lobbies and games. Checked automatically for offensive content (see section 5). |
| Player ID | Generated automatically (random code) the first time you open the Game. | Identifies your account, your token balance and your progress. No sign-up is needed. |
| Apple account identifier (optional) | Only if you choose to link your Apple account in Options. | Lets you recover your account on a new phone. It is an opaque identifier: the Game does not request your name or email from Apple. |
| Google account identifier (optional) | Only if you choose to link your Google account (Google Play Games Services) in Options, on Android. | Lets you recover your account on a new phone. It is an identifier assigned by Google: the Game does not request your name or email from Google. |
| Game data | Created while you play. | Token balance, statistics, reward and weekly-bonus timestamps, cooldowns after leaving a game early, lobby participation. Cards and bets are exchanged live between the players’ devices and are not kept by us after the game, except for the resulting token balance. |
| Messages you send us (optional) | Only if you use Options > Contact us. | Answering your question or request. We receive, by email, the text you write, your player ID, the app version and your device platform. If you write your email address in the message, we use it only to reply. |
| Device identifier | Generated randomly by the Game on your device. | Random code, not linked to your hardware, stored with your account so that it can be used on only one device at a time (the device that signed in last). It is deleted with your account. |
| Technical data | Collected automatically when you use online features and ads. | IP address, device model, operating system, language and app version, used to connect players, keep the service working, prevent abuse and serve ads. |
| Advertising data | Collected by our ad partners when ads are shown. | Advertising identifier (IDFA on iOS, Advertising ID on Android) when you allow it, and interactions with ads (impressions, clicks, completed rewarded videos). |
| Data stored on your device | Created by the Game. | Your settings (sound, music, vibration), your advertising consent choices (recorded by Google’s consent tool, see section 9), and the information needed to rejoin a game after a disconnection. It stays on your device and is erased when you delete your account or uninstall the Game. |
We do not collect your real name, email address (unless you choose to write it in a message to us), phone number, postal address, payment details, precise location, contacts, photos, camera or microphone data. The Game has no in-app purchases.
3. Why we use your data (legal bases)
- To provide the Game (account, online play with friends, tokens, progress): performance of the contract between you and us.
- To keep the Game safe and working (nickname moderation, anti-cheating and abuse prevention, fixing bugs, security): our legitimate interests.
- To personalize ads and to use the advertising identifier: your consent, which we ask for with a consent message where the law requires it. You can refuse or withdraw it at any time (section 8). Non-personalized ads may still be shown.
- To meet legal obligations, where applicable.
4. Who receives your data
We do not sell your personal data. We use the following service providers, who process data on our behalf or under their own responsibility for advertising:
- Unity Technologies – Unity Gaming Services (Authentication, Cloud Save, Cloud Code, Lobby, Relay, Remote Config) host your account and game data and connect players to each other. The Relay service forwards the real-time traffic between players so that players do not see each other’s IP address.
- Unity LevelPlay (ad mediation) and its advertising networks – ironSource Ads and Unity Ads (Unity Technologies, privacy policy) and Google AdMob (Google, privacy policy) – choose, show and measure the ads. They may receive your advertising identifier, IP address (from which they estimate your approximate location), device information and ad interactions, and they act under their own privacy policies. Google’s User Messaging Platform (Google, same privacy policy) displays the consent messages and records your choices. We may add or replace advertising networks over time; this list is then updated.
- Resend (email delivery) – only if you send us a message with Contact us: it carries that message to our mailbox. It acts on our behalf.
- Apple – only if you choose to link your Apple account (iPhone). Apple processes this data under its own privacy policy.
- Google – only if you choose to link your Google account (Google Play Games Services, Android). Google processes this data under its own privacy policy.
- Other players – see your nickname and your actions during a game, which is the purpose of the Game.
We may also disclose data if the law requires it or to protect our rights or the safety of players.
5. Nickname moderation
When you choose or change your nickname, it is checked automatically by a word filter on our server, which refuses offensive nicknames. This check is done on our own server and is not sent to any other company. If a nickname is refused you can simply choose another one. Please do not use your real name or personal information as a nickname, because other players can see it.
6. International transfers
Unity, our advertising partners, our email delivery provider and, if you link it, Google or Apple may process data outside the European Economic Area, including in the United States. Where this happens, the transfer relies on safeguards such as the European Commission’s Standard Contractual Clauses or the EU–US Data Privacy Framework, depending on the provider.
7. How long we keep data
Account and game data are kept for as long as your account exists. When you delete your account, your game data and your authentication account are deleted, and the data stored on your device is erased. Messages you sent with Contact us are kept in our mailbox for up to 12 months, then deleted; deleting your account does not remove emails already received, so ask us (see below) if you want them erased sooner. Technical logs kept by our hosting providers are retained for a limited period. Advertising partners keep data according to their own policies.
8. Your rights and choices
Under the GDPR you have the right to access, rectify, erase, restrict and port your data, to object to processing, and to withdraw your consent at any time without affecting earlier processing. In practice:
- Delete your account and data: see below. This is permanent.
- Change your nickname: in Options (a waiting period between two changes applies).
- Personalized ads: where a consent message is shown (European Economic Area, United Kingdom, and the US states that require it), you can change or withdraw your choice at any time with Options > Privacy choices. On iPhone you can also use Settings > Privacy & Security > Tracking; on Android you can reset or delete your advertising ID in Settings > Privacy > Ads.
- Any other request (access, copy of your data, objection…): write to info@testingames.fr. We answer within one month. We may need to verify that the request comes from the owner of the account.
Delete your account and data
In the Game: open Options and choose Delete account. This deletes your account, your tokens, your progress and the data stored on your device, and it cannot be undone.
Without the app (for example if you have uninstalled it): email info@testingames.fr with your nickname and, if you know it, your player ID (in the Game: Options > Player ID > Copy). We may ask for details so that we can identify your account, and we will delete the data we hold within one month. If you linked an Apple or Google account, you can also remove the Game from the connected apps in that account’s settings.
If you believe your rights are not respected, you can lodge a complaint with your data protection authority. In France this is the CNIL (www.cnil.fr).
9. Advertising and tracking technologies
The Game is free and supported by ads (currently a banner ad). The Game and its ad partners use the following technologies: advertising identifiers; local storage on your device (settings and your choices); session tokens (to keep you signed in to your account); and, in the ad partners’ ad views, cookies or similar technologies. The Game does not use analytics tools such as Google Analytics, nor the Facebook pixel, and does not use retargeting campaigns of our own.
On iPhone, the Game asks for your permission before tracking you across other companies’ apps and websites. The first time you open the Game, where the law requires it, a consent message from Google’s User Messaging Platform asks for your choice about personalized ads before any ad is shown; you can change this choice at any time in Options > Privacy choices. Your choice is stored on your device by this tool. Because the Game runs inside a mobile app, it does not receive “Do Not Track” browser signals.
10. Children
The Game is intended for users aged 18 and over. It contains simulated card gambling with virtual tokens that have no real-world value, and it is not directed at children or minors. We do not knowingly collect data from anyone under 18. If you believe a minor has given us personal data, contact us and we will delete it.
11. Security
We rely on the security measures of our providers, including encrypted connections, and limit access to the data. No system is perfectly secure, so we cannot guarantee absolute security.
12. California residents (CCPA/CPRA and CalOPPA)
In the last 12 months we have collected the following categories of personal information: identifiers (nickname, player ID, advertising identifier, IP address), internet or other network activity (interactions with ads and with the online features) and approximate location derived from the IP address. We collect them for the purposes described in section 3 and disclose them to the providers listed in section 4.
We do not sell personal information for money. When you allow personalized ads, sharing your advertising identifier with our ad partners may count as “sharing” for cross-context behavioral advertising; you can opt out at any time with Options > Privacy choices (where the opt-out message applies to you), or with the iPhone Tracking setting. California residents may ask to know, delete or correct their personal information (in the Game with Delete account, or by email) and will not be discriminated against for exercising these rights.
13. Changes to this policy
We may update this policy, for example when we add a feature or a service provider. The effective date at the top shows the latest version. If a change is significant, we will tell you in the Game.
14. Contact
Hadrien De Ryck (trading as TestinGames) – SIREN 940 152 374 – 6 rue des Tastes, 33460 Soussans, France
Email: info@testingames.fr