Effective: March 1st, 2019
Last update: November 30th, 2022
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.
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
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 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 email@example.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 firstname.lastname@example.org
, 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 email@example.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:
- Age or date of birth
- Email address
- Profile photo
- 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.
- 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 firstname.lastname@example.org.
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
- 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.
- 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.
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.
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 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
Find below a list of Triple Boris’ current third-party service providers and business partners to whom we may share your data.
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.
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
the Applications and to help understand Users’ preferences and improve Users’ experience. Our Applications do not collect cookies.
7.2 Our website
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
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 email@example.com
10.2 Data Protection Officer (DPO)
You can contact our DPO Mr. Simon DANSEREAU at firstname.lastname@example.org
or direct any request to our registered address 203-1463 boul. Lionel-Boulet, Varennes (Québec) J3X 1P7, Canada.
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 email@example.com
Alternatively, you can file a complaint before the Information Commissioner’s Office at https://ico.org.uk/