Politique de confidentialité

2CM STUDIO, a French SAS (simplified joint-stock company) with share capital of EUR 1,500, SIREN 992 690 313, with its head office at 60 rue François Ier, 75008 Paris, France, is the data controller for the personal records described in this policy under the General Data Protection Regulation (EU) 2016/679 (GDPR) and the French Data Protection Act (loi Informatique et Libertés).

The lab operate 2cmstudio.top and publish mobile games as 2CM Studio, an independent game studio. This policy explains what the lab collect, why, how long the lab retain it, who processes it for us and what rights you have.

This policy currently covers the 2cmstudio.top website and email contact or postal letters to the lab with 2CM Studio. The lab do not currently publish any mobile apps, so no app name, package name, SDK or Android permission is described here.

When 2CM Studio 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 2CM Studio website has no accounts, forms, comments or payments. You do not need to give us personal records to read it.

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

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

Because no app is published yet, the lab 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.

The lab use hosting logs only to deliver pages, retain the lab pages secure and investigate faults or misuse; the legal basis is the lab’s legitimate interest under Article 6(1)(f) GDPR.

The lab use letters to the lab to understand your request, reply and retain a record of the lab’s answer, based on legitimate interest, and to meet legal obligations under Article 6(1)(c) where French law requires records.

The lab do not sell personal records, do not use it for advertising or profiling and make no decisions about you by automated means alone.

If the lab ever wanted to use personal records for a new purpose that is not compatible with these, the lab 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 lab pages and acts as the lab’s processor for hosting logs under its data processing addendum. Its policy is at cloudflare.com/privacypolicy.

Any SDK used in a future 2CM Studio 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; the lab do not copy them elsewhere.

The lab retain letters to the lab for up to 12 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 erase your letters to the lab at any time; the lab will do so unless the law requires us to retain 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.

The lab do not knowingly collect personal records from children through it. If a child has written to us, tell us and the lab will erase 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 2CM Studio 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 2CM STUDIO at the address in "Contact us". The lab reply within one month, which may be extended by two further months for complex requests, in which case the lab will tell you why. The lab may ask for reasonable proof of identity, and exercising your rights is free of charge.

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

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

The lab do not transfer letters to the lab 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.

The lab review this policy when the lab 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 2CM STUDIO, "Personal data", 60 rue François Ier, 75008 Paris, France. The lab’s contact page repeats these details.