Privacy Policy

The data controller is: Jules-Camille Doré (Thumbbb Agency), Sole Proprietor (Micro-entrepreneur) SIRET: 879 853 026 00026 SIREN: 879 853 026 EU VAT number: FR37879853026 Address: 77 rue de Campeyraut, 33000 Bordeaux, France Contact: hello@seed.game

For any questions regarding your data, you may contact us at the address above.

We apply the principle of data minimization (Article 5.1.c GDPR). We only collect data strictly necessary for the operation of the service.

Your data is processed for the following purposes:

The only advertising placements in the Application are natively integrated contextual sponsorship campaigns (Takeover Banners), managed directly by the Publisher.

We never sell your identifiable personal data.

Transfers outside the EU: Data transfers to the United States are governed by the European Commission's Standard Contractual Clauses (Decision 2021/914) and, where applicable, the EU-US Data Privacy Framework (DPF).

Anonymized data sharing: Only aggregated and irreversibly anonymized data (sentiment statistics) may be shared with third parties, exclusively subject to your prior consent (see "Data Pact" in Section 3).

• •Active account data: retained for the duration of your use of the service;
• •Data after account deletion: permanently deleted within 30 days, except for data we are legally required to retain;
• •Transaction data (purchases): retained for the legally required period (10 years — French Commercial Code, Article L. 123-22);
• •Anonymized and aggregated data: retained without time limitation (no longer constituting personal data under the GDPR).

We implement appropriate technical and organizational measures to protect your data:

• •Encryption of data in transit (TLS 1.3);
• •Password hashing (bcrypt algorithm);
• •Two-factor authentication (2FA) available;
• •Strict role-based access control;
• •Infrastructure hosted on SOC 2 certified servers.

In the event of a personal data breach, we commit to notifying the CNIL within 72 hours and informing you if the breach is likely to result in a high risk to your rights and freedoms.

Under the GDPR (Articles 15 to 22), the French Data Protection Act, and the Brazilian LGPD, you have the following rights:

• •Right of access (Art. 15): obtain confirmation of processing and a copy of your data;
• •Right to rectification (Art. 16): correct your inaccurate or incomplete data;
• •Right to erasure (Art. 17): request deletion of your data ("right to be forgotten");
• •Right to portability (Art. 20): receive your data in a structured, machine-readable format;
• •Right to object (Art. 21): object to processing based on legitimate interest;
• •Right to restriction (Art. 18): request limitation of processing in certain cases;
• •Right to withdraw consent: withdraw your consent to the "Data Pact" at any time.

We will respond within a maximum of 30 days. If you believe your rights are not being respected, you may file a complaint with the CNIL (www.cnil.fr) or your local data protection authority.

The Application is accessible to users aged 13 and over. For users under 16 (or the minimum age required in their country of residence), parental consent is required in accordance with Article 8 of the GDPR.

We do not knowingly collect personal data from children under 13. If we discover that a child under 13 has provided us with data, we will delete it immediately.

We reserve the right to modify this Privacy Policy. In the event of material changes, we will notify you by notification within the Application at least 15 days before the changes take effect.