1. Who we are
Polarisy is a French simplified joint-stock company, registered with the trade and companies register of Thonon-les-Bains under number 109 193 201, whose registered office is located at 4 avenue de la République, 74100 Annemasse, France. It publishes the website polarisy.com, the Polarisy app intended for users, available on Android and iOS, and the Polarisy Studio app intended for partner merchants.
Polarisy is the data controller for the personal data described in this document. For any question about your personal data or the way we use it, you can write to us at contact@polarisy.com. No data protection officer has been appointed at this time.
2. The data we collect
When you visit the website
When you use the contact form on the website, we collect the name, the email address and the message you enter. In addition, our host and our server process your IP address and connection logs in order to keep the website secure and working properly, in particular through a mechanism that limits the number of requests sent from a single address.
When you use the Polarisy app
To create your account, we collect your email address and the password you choose, which we only keep in encrypted form, or the identifier of your Google account if you decide to sign in with it. You can then complete your profile, optionally, with a name or nickname, a photo, your gender and your phone number.
We then record your activity in the app, meaning the games you take part in, your scores and results, the points you earn and spend, the offers you redeem and the history of all these actions.
If you allow it in your device settings, we use your geographic position to show on the map the businesses that are near you and to offer you deals nearby. When this feature is enabled, we also keep a history of your positions. You remain free to refuse this permission or to withdraw it at any time.
If you agree to receive notifications, we keep an identifier linked to your device that allows us to send you notifications, for example when an offer is available near you or to tell you about a promotion.
Finally, we collect technical data about your device and your use of the app, such as your device model, the version of its operating system, an installation identifier, the language used, the way you navigate the app and error reports. If you choose to watch a rewarded ad, our advertising partner may also process your device's advertising identifier and technical data, as explained in the section on advertising.
When you use the Polarisy Studio app
Merchants create an account with an email address and a password, then provide the name of their business and its contact details, namely the address, phone number, email address, social networks and opening hours. They also create the content they wish to offer, such as games, offers, ads and images. Members of a merchant's team are invited using their email address.
Merchants take out a subscription to publish ads. Payment is handled by a secure payment provider and Polarisy does not keep any bank card data. Polarisy does, however, keep the invoices and the billing information it needs. Using the Polarisy app is free for users, who make no payment.
3. Why we use your data and on what legal basis
We use your data to create and manage your account and to provide you with the app, meaning the games, points, offers and map. This use is necessary for the performance of the contract between you and us, under Article 6(1)(b) of the General Data Protection Regulation. Merchants' subscriptions and their invoicing rest on the same basis, as well as on our legal obligation to keep accounting records.
Showing the businesses and offers near you based on your position, sending notifications, measuring the app's audience and displaying rewarded ads, including personalized ones, rely on your consent under Article 6(1)(a). You can withdraw this consent at any time. Replying to a message you send through the contact form relies on your voluntary decision to write to us.
Error monitoring, which lets us make sure the app works properly and improve the quality of the user experience, the prevention of fraud, cheating and abuse, and the security of our website and infrastructure rely on our legitimate interest in providing a reliable and safe service, under Article 6(1)(f).
4. Who receives your data
Your data is never sold. It is accessible to the Polarisy team and to a limited number of providers who process it on our behalf.
The data of accounts and activity in the apps is hosted in the European Union on the Google Cloud Platform infrastructure, provided by Google. Google also provides the mapping service, the audience measurement and error monitoring tools, and the rewarded ads. When you accept personalized ads, Google's advertising partners, whose full list is shown in the app's consent form, may process your device's data, notably its advertising identifier, to offer you tailored ads. The website and the Polarisy Studio app are hosted by Microsoft, in a data center located in Ireland, and our business email is also provided by Microsoft. Messages sent from the website's contact form are forwarded to an internal messaging tool, in a private space accessible only to members of our team, whose provider is established in the United States.
Partner merchants receive no data that would allow them to identify you. They only access aggregated statistics and, when you redeem an offer with them, an identifier or a QR code that lets them validate that offer without knowing who you are. We may finally be required to disclose data to authorities where the law obliges us to.
5. Transfers outside the European Union
Some of our providers may process data in the United States or in other countries outside the European Union. These transfers are covered by the European Commission's adequacy decision where the provider is certified under the Data Privacy Framework and, failing that, by standard contractual clauses adopted by the European Commission.
6. How long we keep your data
We keep your account and the data associated with it for as long as your account is active. When you ask for your account to be deleted, this data is erased within a maximum of thirty days, following the procedure described on the Account & Data Deletion page. An account that has not been used for three years may be deleted.
Location history is kept for a maximum of twelve months. Messages received through the contact form are kept for a maximum of three years after our last exchange with you, and technical and security logs for a maximum of twelve months. Audience measurement and error data are kept according to the periods specific to the tools used, which do not exceed fourteen months. Invoices and accounting records relating to merchants' subscriptions are kept for ten years, in accordance with the French Commercial Code.
Some data may be kept for longer, in restricted-access archives, where the law requires it or where this is necessary for us to defend a legal claim.
7. Location and notifications
Your position is only used once you have allowed access to location in your device settings. Without this permission, the app remains usable but cannot show you the businesses near you. Notifications are only sent if you have accepted them, and you can turn them off at any time in your device settings.
8. Advertising and audience measurement
The app offers rewarded ads, for example when you choose to watch an ad to be able to replay a game immediately. These ads are provided by Google. Depending on the choices you make in the consent form displayed in the app, they may be personalized using your device's advertising identifier.
You can change or withdraw your consent at any time from the app, and reset or delete your device's advertising identifier from your system settings, under Google settings then Ads on Android, or under privacy settings then Tracking on iOS. If you refuse personalization, non-personalized ads may still be shown to you.
The app's audience measurement is carried out with Google Analytics. It is only activated with your consent, given in the same form, and it only reads and stores the identifiers you have allowed. If you refuse it, no identifier is stored on your device for this purpose, and you can change this choice at any time from the app. Google processes this data on our behalf to produce usage statistics, such as the screens viewed or the features used, which we use to improve the app.
9. Cookies and trackers
The website uses no advertising cookies. Without your consent, it sets only two strictly necessary cookies, which remember your language and your answer to the information banner. With your consent, the home page measures its audience with Google Analytics, as described in the Cookie Policy. The apps use identifiers specific to your device, the details of which are set out in our Cookie Policy.
10. Security
We implement technical and organizational measures suited to the nature of the data we process: encryption of exchanges, user authentication, strict access rules for databases, verification of the authenticity of the apps that communicate with our servers, storage of secrets in a protected space, and computation of game results on our servers rather than on your device. As no system is completely infallible, if a data breach presents a risk to you, we will inform you and the CNIL, as required by law.
11. Your rights
Under the General Data Protection Regulation and French data protection law, you have the right to access your data and to have it rectified, erased, restricted, and ported, and the right to object to its processing. You can withdraw your consent at any time and set instructions about what happens to your data after your death.
To exercise these rights, write to us at contact@polarisy.com. If we have reasonable doubts about your identity, we may ask you to prove it. We reply within one month. If, after contacting us, you believe your rights are not being respected, you may lodge a complaint with the CNIL, 3 place de Fontenoy, TSA 80715, 75334 Paris Cedex 07, France, or on the website www.cnil.fr.
12. Minors
Polarisy is intended for people aged at least 16. We do not knowingly collect data about younger people. If you believe a person under 16 has sent us data, contact us so that we can delete it.
13. Changes to this policy
We may change this policy as our services evolve. In case of a significant change, we will inform you in the app or by email before it takes effect.
14. Contact us
For any question about this policy or your data, write to us at contact@polarisy.com.