PRIVACY POLICY

Effective: March 1st, 2019
Last update: November 30th, 2022

At Triple Boris, we take our users’ privacy very seriously. We commit to being fully transparent about our privacy practices, including how we treat and process your personal information (“personal information” or “data”). We know that you take your privacy seriously as well, so we provide you with the following concise, clear and accessible information about your rights and how we process your data. The terms below explain our processes regarding our privacy practices and are as a whole our privacy policy (“Privacy Policy”). This Privacy Policy is legally binding. Please read it carefully.

1. Parties

This Privacy Policy describes how Triple Boris Inc. (“Triple Boris”, “we” or “us”) processes your personal information in connection with the services offered by Triple Boris as a data controller and/or processor, including but not limited to mobile and other software applications developed and/or sold by Triple Boris (the “Applications”). This Privacy Policy applies when you (“you”, “User”) access, visit or use any of our Applications. For the purposes of this Privacy Policy, a User is a person who downloaded and/or uses a Triple Boris mobile Application. This Privacy Policy does not apply to any third-party applications or software used through Triple Boris’ Applications, or the products, services or activities of others.

2. Consent to the Terms of This Privacy Policy

Triple Boris does not collect any personal information except when Users register an Account with us. Third-party service providers and business partners such as Unity Technologies Inc. (see Section 6 of this Privacy Policy) may collect personal information but Triple Boris does not have access to this personal information.

The use of Triple Boris’ Applications is purely voluntary. You are not required to provide any personal information to us, unless you choose to access features of the Applications that require such personal information. In such a case, if you do not agree with the terms of this Privacy Policy, then please do not provide us with any personal information, exit the Applications immediately, and refrain from using the Applications.

Accordingly, by registering an Account with Triple Boris or by otherwise accessing, visiting or using the Applications, you expressly consent to our collection, recording, organisation, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination, alignment or combination restriction, erasure or destruction (collectively “processing”) of your personal information as described in this Privacy Policy and understand that we may transfer your data outside of the European Economic Area (EEA).

3. Changes to the Privacy Policy

We reserve the right to change our practices and may amend this Privacy Policy from time to time. You may be required to accept the amended Privacy Policy upon logging in to your Account to keep using our Applications. Alternatively, we may post any material changes to this Privacy Policy on our website with a notice advising of the changes in advance and of the effective date of said changes, by sending you an email or any other means of electronic communication. We encourage you to check this page regularly so that you know what our current practices are. If you do not agree with the changes to this Privacy Policy, you may stop using our Applications and delete your Account.

4. Rights to Access, Rectification or Erasure, Restriction and Objection, of Processing and to Data Portability

Subject to any exceptions provided by law, Users have the following rights with regard to our processing of their personal information:

Right to access: Users can find in this Privacy Policy all the information about the way we process their personal information. Where applicable*, Users can access their personal information by clicking on the “Personal Information” button in the in-app Account settings.

Right to rectification: Users can rectify any inaccurate data concerning him or her at any time on their in-app Account settings page.

Right to erasure (also known as “right to be forgotten”): Users can delete their personal information from their Account manually or delete their Account permanently. When Users delete data from their Account, it is permanently deleted from their Account, subject to the circumstances explained at paragraph 9.1. Users may also direct their deletion requests to Triple Boris’ Data Protection Officer (“DPO”) at dpo@tripleboris.com, who will respond to such request within one calendar month.

Right to restriction: Users may restrict the processing of their personal information by Triple Boris where one of the situations listed at Article 18 (1) of the European General Data Protection Regulation (GDPR) applies (accessible at: https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=celex%3A32016R0679). To request data restriction, Users may direct their requests to Triple Boris’ DPO at dpo@tripleboris.com, who will respond to your request within one calendar month.

Right to object: Users may object at any time to the processing of their data by Triple Boris for direct marketing purposes including profiling to the extent that is related to such direct marketing, by clicking on the “Notifications” button in their in-app Account settings page or on the link provided to that effect in Triple Boris’ direct marketing communications.

Right to data portability: Where applicable*, Users may obtain their personal information he or she has provided to Triple Boris by clicking on the “Personal Information” button in the in-app Account settings.

* Not all of our Applications require the registration of an Account with Triple Boris.

Users may also direct us any requests concerning their above-mentioned rights to Triple Boris’ DPO Mr. Simon DANSEREAU at dpo@tripleboris.com

5. Personnal Information about Users

5.1 Information We May Collect or Receive

We receive personal information about Users of our Applications primarily in two ways:

Actively: When Users voluntarily provide us with personal information. For example, when a User registers an account with us, he or she will type in a name, username, email address and may be required to provide a date of birth and/or other information.
Passively: Our systems automatically collect personal information about devices and game activity when a User uses one of our Applications.

i. Information that Users Actively Provide, Including:

Name
Age or date of birth
Gender
Username
Email address
Profile photo
Avatar
OAuth credentials
Physical or mailing address
Phone number
Password(s) that User create to access the Applications and/or parts of the Applications;
Notifications preferences
Billing or financial account information: When Users provide payment (e.g. credit card) information to make an in-app purchase, that information is sent to payment processors who assist Triple Boris. Our payment systems are not designed to store credit card numbers or any financial information.
Social network information: When you log in to our Applications with a social network account, you may have the option to share information such as the name you use on that network and your friends list or other information that the third-party social network chooses to share with us, depending on their privacy policy.
Users may share information with us that we store on their behalf and use to enhance their experience. For example, we collect and store feature requests when Users ask for features or improvements to be implemented in our Applications or when Users otherwise provide us with testimonials through the “Contact” page of our website.
Help requests: We collect and store help requests submitted by Users through the “Contact” page of our website or via email at support@tripleboris.com.

ii. Information that is Passively Collected by Triple Boris

User device information: When Users access our Applications and/or receive ads by Triple Boris, we may collect some or all of the following information through a third-party service provider or business partner as an Analytics tool:

– Unique device identifier generated from the device MAC/IMEI/MEID, which we alter to limit the ability to identify the relevant device in the future;

– An advertising ID, such as the Apple IDFA or the Android Ad ID;

– IP address;

– Device manufacturer and model;

– The operating system and version running on your device; and

– Language.

Location information: Our systems (like most used on the web) automatically collect an IP address when Users access the Application. IP addresses can be used to learn about the general location (e.g. city, state or province and country) of the User’s point of access to the Applications.
Usage data: We collect usage data about Users whenever they use our Applications, including date and time of access and information they have elected to make publicly available.
Referral data: If Users download our Applications from an external source (such as a third-party website redirecting Users to the Application downloading page), we collect information about the source that referred said Users to us.
Cookies (see Section 7 of this Privacy Policy)
Other information: We may obtain additional information about Users from third parties such as marketers, partners, researchers and others. We may combine information that we collect from you with information about you that we obtain from such third parties and information derived from any other subscription, product or service we provide.

5.2 Triple Boris’ Obligations to Users as Data Controller and Data Processor

For the processing of Users data, Triple Boris undertakes to fulfil the following obligations:

a) To treat at any given time your data only in connection with the services offered through our Applications (unless there is a legal rule that requires complementary processing, in such a case, Triple Boris will inform the User of that legal requirement prior to the processing, unless the law prohibits it on public interest grounds).

b) To maintain the duty of secrecy with respect to Users data which Triple Boris has access to, even after you stop using the Applications and/or delete their Accounts, and to ensure that our employees and third-party processors have committed in writing to maintain the confidentiality of the data being processed.

c) To ensure, taking into account the available technology, the costs of implementation, and the nature, scope, context and purposes of the processing, that we apply adequate technical and organizational measures to ensure a level of security appropriate to the risk, including, where appropriate, among other things:

Pseudonymization and encryption of data;
The ability to ensure the continued confidentiality, integrity, availability and resilience of the systems and Applications;
The ability to restore the availability and access to data quickly and resilience of the systems and Applications;
The regular verification, evaluation and assessment of the effectiveness of the technical and organizational measures to ensure safety of processing.

When evaluating the adequacy of the security level, special account shall be taken of the risks presented by data processing, in particular as a consequence of the destruction, loss or accidental or unlawful alteration of the data transmitted, stored or otherwise processed, or the communication or unauthorized access to such data.

In the event that the implementation of specific and concrete security measures is needed, those measures will be added to this Privacy Policy.

d) To keep under our control and custody the data to which we have access in relation with the use of the Applications, and not to disclose them, neither transfer or otherwise communicate them, not even for their preservation, to persons unrelated with the use of the Applications covered by this Privacy Policy.

However, we may authorize, expressly and in writing, third-party service providers and business partners, whose details are listed at paragraph 6.5 of this Privacy Policy. We will notify you of any expected change to the aforementioned list.

In any case, access to the data made by natural persons who render services to Triple Boris, acting within the organizational framework of the latter by a commercial non-labour relationship and having agreed in writing to maintain the confidentiality of the data processed is authorized. In addition, access to the data is granted to companies and/or professionals that Triple Boris hires in its internal organizational framework to provide general maintenance services (computer, services, consulting, audits, etc.).

e) To delete or return to Users, at their discretion, all data to which we have access, unless there is a legal rule that requires the preservation of data.

f) To notify Users, without delay, of any personal security breach of which we are aware, to provide support to Users in notifying the competent control authority and, if applicable, the interested parties of the security breach that occur, as well as to provide support, where necessary or appropriate, in the carrying out of privacy impact assessments and in the prior consultation to the control authority.

g) To make available to Users all the information necessary to demonstrate the fulfilment of the obligations established under the Privacy Policy.

6. Using and Sharing Personal Information for Legitimate Business Purposes

6.1 We primarily use your personal information to provide, administer, operate and improve our Applications.

6.2 We may use your personal information for the following purposes:

To create, administer and troubleshoot Accounts in the Applications;
To credit or accept payments;
To provide technical and customer support, respond to inquiries and fulfill your requests;
To perform in-house statistical analysis identifying and measuring Users trends, popularity of products and services, to improve and optimize the performance, efficiency and usability of the Applications;
To create and share statistics and reports regarding aggregate usage of our Applications;
To test changes and improvements of the Applications and to personalize Users experience;
To monitor troubleshooting and prevent abusive activity (e.g. fraud, spam, phishing activities);
To prevent fraud, enforce this Privacy Policy, our licenses, protect Users and for other forms of security monitoring;
To comply with applicable laws and cooperate with law enforcement;
To deliver and target advertising, including personalized ads;
To inform Users of new Applications or other products and services, including promotional offers; and
For research and development purposes, for developing new products and services or for otherwise operating and expanding our business activities.

6.3 If you connect with other third-party applications, we may use the information that you make available through the applicable third-party application and that the third-party application has made available to Triple Boris, in accordance with the privacy or other settings that are applicable to the third-party application.

6.4 We may use your personal information to send you information that we believe will be of interest to you such as Triple Boris product intro, tips and inspirational use cases and User stories by any means, including email and similar means of electronic communication like personalised advertisements as part of providing relevant content helpful to use our Applications efficiently. To customize such information and commercial communication as much as possible, Triple Boris may use statistical techniques that allow the creation of User profiles and data segmentation.

6.5 We do not sell your data to third parties without your permission. We share your personal information with our third-party service providers and business partners who help us develop Applications, in which case those third-party service providers and business partners are bound by contract to comply with this Privacy Policy and any other adequate technical and organizational measures so as to keep your data confidential.

Find below a list of Triple Boris’ current third-party service providers and business partners to whom we may share your data.

NAME	PURPOSE	SHARED DATA
Unity Technologies, Inc. Click here for privacy policy	To improve the Unity software and services we use to develop our Applications	All of the above Information We May Collect or Receive

6.6 Triple Boris is based in Canada and complies with the GDPR framework as set forth by the European Union regarding the processing of data from residents of EU member countries. If you do not want your personal information transferred or processed in the EU or in other non-EU countries, you should not use the Applications.

If you are located in the EU, we guarantee that we will only transfer your data to third-party service providers and business partners that are bound by contract to comply with this Privacy Policy or that are registered with the Privacy Shield, to ensure a level of data protection compliant with the GDPR. If such third-party service providers and business partners are based in countries which do not have legislation on data protection which is equivalent to the EU legislation, Triple Boris shall establish all safeguards required by the EU in order to comply with all obligations arising such transfers of data (the full list of countries that provide an adequate level of data protection according to EU standards is available at: https://ec.europa.eu/info/law/law-topic/data-protection/data-transfers-outside-eu/adequacy-protection-personal-data-non-eu-countries_en).

Please note that no system can be guaranteed to be 100% secure. Therefore, while we strive to employ reasonable protections of your data that are appropriate to its sensitivity, we cannot guarantee or warrant the security of the personal information you share with us and we cannot be responsible for the theft, destruction, loss or inadvertent disclosure of your personal information.

6.7 Your data is not otherwise disclosed to any third party except when we believe in good faith that it is necessary or appropriate (i) under applicable law, including laws outside your country of residence; (ii) to comply with legal process; (iii) to respond to requests from competent public and government authorities in the exercise of their duties (e.g. to investigate, prevent or take action regarding illegal activities), including authorities outside your country of residence; (iv) to enforce this Privacy Policy; (v) to protect our operations, rights, safety or property and/or that of any of our affiliates, you or others; (vi) to allow us to pursue available remedies or limit the damages that we may sustain; and (vii) when we otherwise have your permission under this Privacy Policy.

6.8 We do not use your personal information other than as described in this Privacy Policy and we do not share your personal information with any third parties for their direct marketing purposes.

7. Cookies

7.1 For the purposes of this Privacy Policy, a cookie is a small string of information that the Applications you use transfer to your mobile device for identification purposes, to follow your activities throughout the Applications and to help understand Users’ preferences and improve Users’ experience. Our Applications do not collect cookies.

7.2 Our website however does collect cookies. For detailed description of the types of cookies we may use and on how you can control the use of cookies, contact our DPO at dpo@tripleboris.com.

8. Modifying Personal Information, Opting Out of Email and Cancelling your Account

8.1 You may modify your personal information by logging in and visiting your in-app Account settings page. You can also ask for instructions by sending us a message through the “Contact” page of our website.

8.2 We will respond to any request to access, correct, update or delete your personal information within the time period specified by law (if applicable) or without excessive delay. We will promptly fulfill deletion requests.

8.3 You may also cancel your Account and/or opt out of receiving any email from Triple Boris at any time in your in-app Account settings page or on the link provided to that effect in Triple Boris’ email. Subject to what follows, deleting your account will permanently delete your personal information from our systems within a reasonable time period, as permitted by law and will disable your access to any other Applications that require an Account registered with Triple Boris.

8.4 We encourage you promptly to update your personal information when it changes. Information concerning your past use of the Applications may be retained by Triple Boris as long as necessary for the purposes set out below.

9. Retention of Your Information

9.1 We retain personal information for active Triple Boris Accounts as long as it is necessary and relevant for our operations. In addition, we may retain personal information from closed accounts and/or refuse to fulfil a User’s deletion request to comply with the applicable law, prevent fraud, collect any fees owed, resolve disputes, troubleshoot problems, assist with any investigation, enforce this Privacy Policy, take other actions permitted by the law or if a User’s deletion request is not otherwise technically feasible. If required by law, we may block access to such data.

9.2 The data we retain will be handled in accordance with this Privacy Policy during the maximum terms permitted by law and will exclusively be used for purposes set forth in this Privacy Policy. After those terms, your personal information will be fully deleted or, alternatively, anonymized.

10. How to Contact Us

10.1 Support and Feature Requests

You can send a request, question, feedback, complaint or feature request through the “Contact” page of our website. In the alternative, you can send a request to our team at support@tripleboris.com.

10.2 Data Protection Officer (DPO)

You can contact our DPO Mr. Simon DANSEREAU at dpo@tripleboris.com or direct any request to our registered address 203-1463 boul. Lionel-Boulet, Varennes (Québec) J3X 1P7, Canada.

11. Complaints

If you consider that any use of your data might breach any of your rights, you can lodge a complaint at any time by contacting our DPO Mr. Simon DANSEREAU at dpo@tripleboris.com.

Alternatively, you can file a complaint before the Information Commissioner’s Office at https://ico.org.uk/