ABOUT

The terms “we”, “us” or “our” used within this privacy policy are referred to the company:

“Neuf Octobre”and "Clement Vitroly", located at 52 route de Lavérune, 34070 Montpellier, France.

By using our apps such as “Pu the panda”, “Bu the bunny”, “Inu the shiba” and “Oz the creature” or our

websites, you agree and consent to the collection, use, disclosure and sharing of your personal information

and your personal data as described in this privacy policy.

This Privacy Policy is part of and incorporated by reference into the End User License Agreement (the “EULA)

governing the use of all “Neuf Octobre” and "Clement Vitroly" Applications.

For any questions regarding our privacy policy, you may contact us at this email address:

support@9octobre.com

CHILD PROTECTION

Our apps are destined to any public but we have implemented an age limit that deactivates all features that

allow the collection, use, disclosure and sharing of personal data for children under the age of 16 according to

EEA data protection legislation (GDPR) and under the age of 13 in specific territories (US included) according

COPPA legislation.

We do not voluntarily collect personal data for children under the age limit according the legislation, with the

sole exception of their year of birth and persistent identifiers as described below. We do not store or share the

users’ age but only the fact that their age is below the limit.

Persistent identifiers (such as anonymous user ID, IP address, IDFA, IDFV, ID or IMEI for Android devices,

advertising identifiers) are used and shared for providing our advertising partners with the information stating

that the user is under the age limit. At our request, our advertising partners undertake to meet the same

requirements as us with regards to the privacy policy concerning children and limit the usage of information

collected to meet the legal requirement. Therefore, they are allowed to serve contextual advertising, providing

analyses regarding the app, the game industry and the device used, and authenticating users to ensure

compliance with legal requirements. We cannot be held responsible in case of breaches in their commitments.

If we become aware that we are storing personal data regarding a child under the age limit according the

legislation, we undertake to delete the data within a reasonable time and without the need for a

disproportionate technical effort.

DATA COLLECTION AND USE

Data collected by us:

The personal data that we collect, that does not identify you, is your year of birth. In addition we collect

technical information related to your device such as your storage size, screen size, installed apps, network

status, access to internal and external storage, time zone, mobile phone carrier, device language, locale,

country code.

The collection of the year of birth only allows us to define whether the player is under the age limit. It is not

shared, nor disclosed, nor stored.

Technical data is used to guarantee the app’s functioning, to customize its content, to serve ads and to meet

the legal requirement. They are not stored, nor shared, nor disclosed.

The only personal data we collect that may lead to your identification are the email addresses that allow

players to communicate with us if they wish to.

They are only used for the purposes for which players provide them to us. We do not store, nor share, nor

disclose email addresses.

Email addresses and messages contents are deleted immediately.

Data collected by third parties:

Some of our third-party services may collect and use persistent identifiers such as anonymous user ID, IP

address, IDFA, IDFV, ID or IMEI for Android devices, advertising identifiers.

Persistent identifiers make it possible to collect data that does not identify you personally but only identifies

your device. Some legislation (such as US or GDPR) may treat such information as personal information.

This data is used by our partners for app-level analytical purposes, to display interest-based, targeted or

contextual advertising, to analyze and report anonymized and aggregate-level information about devices, apps

and the game industry and authenticating users to ensure compliance with legal requirements.

To learn more about the data our third-party partners may collect and use, please refer to their own privacy

policies, available in the “third-party services” section.

The Information are used only for limited purposes as stated in Section “Data collection and use” taking into

account the limitations regarding collection and usage of certain Information in Section “Child protection”.

THIRD-PARTY SERVICES

Advertising:

When using our Apps you may be offered advertising content. The advertising networks we use may utilize

ad-serving technology that uses cookies, tags, web beacons, and other technologies placed in ads, as well as

advertising identifiers that aim to enable the display of appropriate advertising and to evaluate the

performance of their advertising campaigns. We make every effort to ensure that the data collected, used and

shared by third-party services meets the standards in our privacy policy and in particular in the child

protection policy in order to comply with the relevant legislation.

We do not have any direct control over the collected and used data, therefore we cannot in any case be held

responsible for the violation of the privacy policy by our partners.

Here are the links to the privacy policies of the third-party services that we use:

Facebook Audience Network : https://www.facebook.com/about/privacy/update?ref=old_policy

AppLovin : https://www.applovin.com/privacy/

IronSource : https://developers.ironsrc.com/ironsource-mobile/air/ironsource-mobile-privacy-policy/#how-to-control-your-info

Chartboost : https://answers.chartboost.com/en-us/articles/200780269; https://answers.chartboost.com/en-us/articles/207222586

AdColony : https://www.adcolony.com/privacy-policy

Unity : https://unity3d.com/legal/privacy-policy

AdMob : https://support.google.com/admob/answer/7665968; https://support.google.com/dfp_premium/answer/9012903

Third-party networks:

Our apps use services such as “Google Play” or “Game Center” registration or login. You may sign in or out of

these services at any time using a feature that is built into our apps.

It is also possible to share the content you have created within the apps via messaging services or third-party

social networks.

These services are governed by their own privacy policies and terms and conditions. We cannot be held

responsible for their practices.

Here are the links to the privacy policies of the services that we use:

Google Play : https://play.google.com/intl/en-us_us/about/play-terms.html

Game Center : https://www.apple.com/legal/internet-services/itunes/gamecenter/

External websites:

Our apps are linked to external websites such as links to third-party websites, products or services that are

beyond our control.

By accessing external websites, you agree to their privacy policies. Please note that external websites may

have privacy policies that differ from our own as to the collection, use, disclosure and sharing of your data,

they are governed by their own privacy policies.

We have no control over these third parties’ privacy practices and you hereby acknowledge that we cannot be

held responsible for your interactions with such third parties.

IN-APP PURCHASES

Our apps offer in-app purchases. Transactions are carried out via your app store account. They are controlled

and governed by said app store’s terms and conditions. We will not have access to any data regarding your

credit card or payment method.

We reserve the right to refuse a purchase refund for any wrongful or repeated request.

For more information on in-app purchases in our Apps please see In-App Purchases Section of the End User

License Agreement available at : http://9octobre.com/Eula_EN.html

NOTIFICATIONS

Our apps offer local and contextual notifications to players, with their consent, in the form of a message

inviting the player to reopen the application.

It is possible to disable notifications at any time by following the instructions below:

. Go to the "settings" menu of our applications and press the "notifications" button to disable or enable

notifications.

INTEREST-BASED ADVERTISING

Interest-based or retargeted advertising is displayed within our apps only if the identifier shows that the user is

above the age limit and that interest-based advertising is enabled.

We will not process or pass your information for the purposes of Interest-based or retargeted advertising on to

third parties unless you give your consent or you have given it already according to EEA data protection

legislation (GDPR). After you have given your consent, you may withdraw it at any time.

Therefore, you agree to the fact that the collected data may be used for targeted or interest-based advertising.

Our third-party services may also collect and use data from other apps and websites or other services and

share them with each other in order to create profiles.

This data is described in the “collected and used data” section.

If you are a California resident, you have the right to opt out of the “sale” of their “personal information” (as

the law (CCPA) defines those terms). CCPA recognizes certain exceptions to the definition of “sale,” such that

not all transfers of personal information are “sales.” For example, transferring personal information to a

“service provider” under the law is not a sale.

Please find below the list of third-party services that we use and a procedure to opt out of the sale of your

personal information and data for the purposes of interest-based advertising for each provider.

Facebook Audience Network : https://www.facebook.com/ads/preferences/?entry_product=ad_settings_screen

AppLovin : https://www.applovin.com/optout

IronSource : https://developers.ironsrc.com/ironsource-mobile/air/ironsource-mobile-privacy-policy/

Chartboost : https://answers.chartboost.com/en-us/articles/200780269#donottrack

AdColony : https://www.adcolony.com/privacy-policy/#targetingchoices

AdMob : https://www.google.com/ads/preferences/html/mobile-about.html

Unity : https://unity3d.com/legal/privacy-policy

You may also opt out of the list for all providers by following the procedure below:

. Enable “Limit Ad Tracking” on your iOS device or “Opt out of ads personalization” on your Android device.

All advertising service providers will be required to comply with your opt out.

We cannot be held responsible for breaches in their commitments.

RETENTION

We do not store personal information. We delete information as soon as we no longer need it for the purposes

described in this Privacy Policy.

YOUR RIGHTS

You have certain rights in connection with your personal information and how we and our partners handle

them.

If you are an EEA user, you are always free to request limitations to the processing of your personal

information, data deletion or object the processing of your information by uninstalling our Apps. You can also

exercise your right to data portability.

For any purpose please contact us.

We remind European users that they have a right to lodge a complaint with European Data Protection

Supervisor.

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Updates to our privacy policy:

We reserve the right to make changes to our privacy policy.

Please consult it regularly in order to keep up-to-date with the changes made to it.

Please note that you must update to the latest version of the app for this privacy policy to apply.

Last Update May 2020