Politique de confidentialité

3FORTSOFT, a French SAS (simplified joint-stock company) with share capital of EUR 1,500, SIREN 989 618 509, with its head office at 91 route des Romains, 67200 Strasbourg, France, is the data controller for the data about individuals described in this policy under the General Data Protection Regulation (EU) 2016/679 (GDPR) and the French Data Protection Act (loi Informatique et Libertés).

3FortSoft operate 3fortsoft.im and publish mobile games as 3FortSoft, an independent game studio. This policy explains what 3FortSoft collect, why, how long 3FortSoft keep it, who processes it for us and what rights you have.

This policy currently covers the 3fortsoft.im website and email contact or postal letters to Strasbourg with 3FortSoft. 3FortSoft do not currently publish any mobile apps, so no app name, package name, SDK or Android permission is described here.

When 3FortSoft releases a game on Google Play in the future, that app will receive a separate policy on this site, naming the app and its package and following its Google Play Data Safety answers.

The 3FortSoft website has no accounts, forms, comments or payments. You do not need to give us data about individuals to read it.

3FortSoft’s hosting provider processes technical edge network logs on 3FortSoft’s behalf: IP address, requested page, time, browser type and, if sent, the referring page. 3FortSoft do not combine this data with any other source and do not use it to identify individual visitors.

If you write to us, 3FortSoft receive your name, return address and anything you include. Please do not send passwords, payment details, health data or identity documents.

Because no app is published yet, 3FortSoft have no Data Safety declaration to report. Each future app policy will follow the Data Safety categories and say whether data stays on the device or leaves it.

3FortSoft use edge network logs only to deliver pages, keep the castle pages secure and investigate faults or misuse; the legal basis is 3FortSoft’s legitimate interest under Article 6(1)(f) GDPR.

3FortSoft use letters to Strasbourg to understand your request, answer and keep a record of 3FortSoft’s answer, based on legitimate interest, and to meet legal obligations under Article 6(1)(c) where French law requires records.

3FortSoft do not sell data about individuals, do not use it for advertising or profiling and make no decisions about you by automated means alone.

If 3FortSoft ever wanted to use data about individuals for a new purpose that is not compatible with these, 3FortSoft would update this policy first and, where the law requires it, ask for your consent.

The website includes no analytics, advertising, social plugins, external fonts or third-party SDKs.

Cloudflare, Inc. hosts the castle pages and acts as 3FortSoft’s processor for edge network logs under its data processing addendum. Its policy is at cloudflare.com/privacypolicy.

Any SDK used in a future 3FortSoft app will be named, with a link to its policy, in that app’s own policy.

Cloudflare keeps request logs for a short period under its own settings; 3FortSoft do not copy them elsewhere.

3FortSoft keep letters to Strasbourg for up to 18 months after a matter is closed, unless a longer period is needed to establish or defend a legal claim or to comply with French law.

You may ask us to delete your letters to Strasbourg at any time; 3FortSoft will do so unless the law requires us to keep it, and will tell you if so.

The website is a general company site for players, parents and business contacts and is not directed at children under 15, the age of digital consent in France.

3FortSoft do not knowingly collect data about individuals from children through it. If a child has written to us, tell us and 3FortSoft will delete the message. Each future game policy will state its intended audience.

The website requests no device permissions. Visiting it never asks for your camera, microphone, location, contacts, photos, files or notifications.

When 3FortSoft publishes an Android game, its policy will list every permission in the released build and explain why it is needed.

Under the GDPR you may ask for access to your data, correction, erasure, restriction, objection and portability where applicable. Under French law you may also give instructions about your data after your death.

Write to 3FORTSOFT at the address in "Contact us". 3FortSoft answer within one month, which may be extended by two further months for complex requests, in which case 3FortSoft will tell you why. 3FortSoft may ask for reasonable proof of identity, and exercising your rights is free of charge.

Where processing relies on 3FortSoft’s legitimate interest, you may object at any time on grounds relating to your particular situation, and 3FortSoft will stop unless 3FortSoft have compelling legitimate grounds.

You may lodge a complaint with the Commission nationale de l’informatique et des libertés (CNIL), 3 place de Fontenoy, TSA 80715, 75334 Paris Cedex 07, or at cnil.fr.

3FortSoft are based in France, inside the European Economic Area, so most letters to Strasbourg never leaves the EU. Cloudflare operates a global network, so edge network logs may be processed outside the European Economic Area, including in the United States.

3FortSoft do not transfer letters to Strasbourg outside the EEA ourselves. Such hosting transfers rely on the EU-US Data Privacy Framework, under which Cloudflare is certified, and on the European Commission’s standard contractual clauses included in Cloudflare’s data processing addendum.

3FortSoft review this policy when the castle pages changes, before a game is released and when the law changes. The date and version at the top show the latest change; material changes will be highlighted on this page.

Earlier versions are kept on file and can be sent on request, so you can see exactly what changed and when, together with the reason for each revision.

Write to 3FORTSOFT, "Personal data", 91 route des Romains, 67200 Strasbourg, France. 3FortSoft’s contact page repeats these details.