Privacy Policy: Daily's World

Welcome to Daily's World.

At Pragma Infodev SAS, we respect your privacy and we are committed to protecting your personal data.

The purpose of this Privacy Policy is to tell you how we collect, use, retain and protect your personal data when you use the Daily's World mobile application (hereinafter the "Application").

It is drawn up in accordance with the General Data Protection Regulation (Regulation EU 2016/679, hereinafter the "GDPR") and the French Data Protection Act. It also applies to Users residing in countries not covered by the GDPR, who additionally benefit from the rights granted by their own regulations, in particular the UK GDPR in the United Kingdom, the Federal Act on Data Protection (nFADP) in Switzerland and Law No. 1.565 of 3 December 2024 in Monaco.

Article 1: Data controller

The controller of your personal data is:

• Pragma Infodev SAS
• Simplified joint-stock company (société par actions simplifiée) with share capital of €1,000
• Registered office: 6 Rue de Presbourg, 75116 Paris, France
• Paris Trade and Companies Register (RCS Paris): 883 292 724
• Contact: contact@pragma-infodev.com

Pragma Infodev SAS is established in France and processes all of the Application's data there. Whatever your country of residence, requests relating to your data should be sent to us directly, at the address above.

No Data Protection Officer (DPO) has been appointed. Data protection requests are handled directly by the Publisher, at contact@pragma-infodev.com.

Article 2: Data we collect

We collect only the data strictly necessary for the operation of the Application and the provision of our services. That data breaks down as follows.

2.1 Account data

When you create and manage your account, we process:

• your email address;
• your password, stored in encrypted form (hashed), never in plain text;
• your username;
• your date of birth (used in particular to verify the age requirement);
• your country of residence;
• a technical identifier for your device (deviceId);
• technical information about your device (operating system).

2.2 Game and activity data

As part of your use of the Application, we process data relating to your activity:

• your progression, levels, scores and rankings;
• your virtual resources (dice, in-game coins, cards, tickets, tokens, trophies);
• your game history (lottery, draws, challenges, and so on);
• your Clan membership and your participation in collective features;
• the messages you send in the Clan chat;
• the reports you make or that concern you.

2.3 Technical, connection and stability data

For security and proper operation, we process your IP address, connection logs and information relating to your sessions.

We also process crash reports, collected through Firebase Crashlytics. Those reports contain technical information about the state of the device at the time of the incident and are used exclusively to fix defects in the Application.

2.4 Usage and audience measurement data

We process aggregated usage data (screens viewed, features used, progression events) through Firebase Analytics, in order to understand how the Application is used and to improve it.

2.5 In-app purchase data

When you make an in-app purchase, the transaction is processed by the distribution platform (Google Play or Apple App Store). We receive the information necessary to deliver the purchased content and to manage your account, but we have no access to your banking data, which is processed directly by the platform.

The technical management of those purchases and of the associated entitlements is handled by our provider RevenueCat, which processes your account identifier, your purchase history and the status of the content you have acquired.

2.6 Data collected by our advertising and measurement partners

The Application uses Google AdMob to display advertising, and the Meta SDK to measure the effectiveness of our campaigns.

Subject to your consent, the following data may be transmitted to them:

• your device's advertising identifier (IDFA on iOS, AAID on Android);
• your approximate location;
• your interactions with advertisements;
• application events (install, open, purchase);
• technical data (device type, operating system, language).

Without your consent, your device's advertising identifier is not read and this data is not transmitted.

2.7 Platform declarations

All categories of data we collect, how we use them and how we share them are also declared on our product pages, in the App Privacy section of the App Store and in the Data Safety form on Google Play.

Article 3: Purposes and legal bases

Your data is processed for the following purposes and on the following legal bases:

We do not collect any directly identifiable personal data for commercial or marketing prospecting purposes on our own behalf.

Article 4: Consent to advertising tracking

The display of personalised advertising and advertising measurement are based on your consent.

That consent is collected within the Application, on first launch, through the consent management platform Google UMP (User Messaging Platform). That screen lets you accept or refuse, purpose by purpose, and change your choice at any time.

On iOS, an additional system window, App Tracking Transparency, asks for your permission to access your device's advertising identifier.

• If you accept, certain data may be used to offer you personalised advertising and to measure its effectiveness.
• If you refuse, your device's advertising identifier is not read, no data is transmitted to our advertising partners for personalisation purposes, and non-personalised advertising is shown to you.

You can change your choice at any time from the Application's settings. Withdrawing consent does not affect the lawfulness of processing carried out before that withdrawal.

Article 5: Recipients and processors

We do not sell your personal data and we do not share it with third parties for their own commercial purposes.

Your data may be disclosed to the following providers, acting as processors or recipients, strictly within the purposes described above:

Your data may also be disclosed to the competent administrative or judicial authorities where required by law.

Article 6: Location and transfers of data

6.1 Hosting

The Application's data is hosted and stored exclusively on servers located in France, in the AWS Europe (Paris) region.

6.2 Users residing outside the European Union

If you reside in the United Kingdom, Switzerland, Monaco, Andorra or San Marino, your data is processed and stored in France, and therefore outside your country of residence.

That transfer benefits from a recognised framework: the United Kingdom and the European Union mutually recognise an adequate level of protection, and Switzerland recognises the European Economic Area as offering an adequate level of protection. For the other countries concerned, processing is carried out under the protection of the GDPR, whose requirements are at least equivalent to those of your national legislation.

6.3 Transfers to third countries

Some of our providers (in particular Google, Meta, RevenueCat and Microsoft) may process data outside the European Union, mainly in the United States. Those transfers are covered by appropriate safeguards in accordance with the GDPR, in particular certification under the EU to US Data Privacy Framework, the European Commission's standard contractual clauses, or any other mechanism recognised as offering an adequate level of protection.

Article 7: Retention periods

We retain your personal data for no longer than is necessary for the purposes for which it is processed.

You stay in control at all times. You can view, change and delete your data directly from your personal space within the Application, without having to ask us and without waiting for the periods above to expire. Only data that the law requires us to keep, in particular accounting data relating to purchases, is retained beyond that point.

Article 8: Data security

We implement appropriate technical and organisational measures to protect your data against unauthorised access, loss, alteration or disclosure, in particular:

• storage of passwords in encrypted form (hashing);
• use of secure connections and authentication tokens for exchanges with our servers;
• hosting of data in France with a recognised provider.

Article 9: Your rights

In accordance with the applicable regulations, you have the following rights over your personal data:

• a right of access: to obtain confirmation that your data is processed and to obtain a copy of it;
• a right to rectification: to correct inaccurate or incomplete data;
• a right to erasure: to request deletion of your data;
• a right to portability: to receive your data in a structured, machine-readable format;
• a right to restriction of processing;
• a right to object to the processing of your data, in particular where it is based on legitimate interest;
• a right to withdraw your consent at any time, for processing based on consent (for example, personalised advertising);
• a right to give directions concerning the fate of your data after your death, in accordance with Article 85 of the French Data Protection Act.

9.1 Exercising your rights directly in the Application

Most of these rights can be exercised directly, without writing to us. From your personal space within the Application, you can at any time view your data, change it, and delete or anonymise your account together with the associated data. The effect is immediate and irreversible.

9.2 Exercising your rights with us

For any other request, you can contact us at contact@pragma-infodev.com. We may ask you to prove your identity in order to protect the security of your account.

We respond within one month of receiving your request. That period may be extended by a further two months where the request is complex or where a number of requests have been received; we will inform you of that extension within one month of your request, together with the reasons for it.

Article 10: Lodging a complaint with a supervisory authority

If you consider that your rights are not being respected, you have the right to lodge a complaint with the competent supervisory authority, which is in principle the one in your country of residence.

In France, the controller's supervisory authority:

• CNIL, 3 Place de Fontenoy, TSA 80715, 75334 Paris Cedex 07, France
• https://www.cnil.fr

In the other countries of the European Economic Area, the full list of national authorities is maintained by the European Data Protection Board:

• https://www.edpb.europa.eu/about-edpb/about-edpb/members_en

In countries not covered by the GDPR:

• United Kingdom: Information Commissioner's Office (ICO), https://ico.org.uk
• Switzerland: Federal Data Protection and Information Commissioner (FDPIC), https://www.edoeb.admin.ch
• Monaco: Personal Data Protection Authority (APDP), https://www.apdp.mc

Article 11: Protection of minors

The Daily's World Application is strictly reserved for adults, aged at least 18 years.

We do not knowingly collect personal data concerning minors. If we learn that an account has been created by a minor, we will delete the account and the associated data.

In accordance with Article 5 of the Terms of Use, we reserve the right to request proof of age at any time and to suspend access to the account pending its production.

Article 12: Trackers and advertising identifiers

The Application uses your device's advertising identifier, subject to your consent, through Google AdMob and the Meta SDK, in order to display advertising, personalise it and measure its effectiveness.

Without your consent, that identifier is not read.

You can change your choice at any time from the Application's settings, and reset or limit the use of your device's advertising identifier from your system's privacy settings (iOS or Android).

Article 13: No automated decision making

No decision producing legal effects concerning you or significantly affecting you is taken solely on the basis of automated processing.

In particular, the moderation measures and the account suspensions or deletions provided for in Article 12 of the Terms of Use are reviewed and approved manually by our team. The automated tools used to detect fraud, multi-accounting or abuse serve only to flag situations for review, never to decide on their own.

Article 14: Changes to this policy

We may amend this Privacy Policy, in particular to reflect legal, technical or functional changes. The date of the latest update appears at the top of this document. In the event of a material change, we will inform you by an appropriate means within the Application.

Article 15: Language of the document

This Privacy Policy is drawn up in English. The English version is the reference version and prevails.

It is made available in the other languages in which the Application is offered. In the event of any discrepancy of interpretation between the English version and a translated version, the English version prevails.

This provision may not deprive the User of the benefit of the mandatory provisions of the law of their country of habitual residence.

All language versions are available within the Application and at https://www.worldwildgames.com.

Article 16: Contact

For any question relating to this Privacy Policy or to the processing of your personal data:

• Email: contact@pragma-infodev.com
• Postal address: Pragma Infodev SAS, 6 Rue de Presbourg, 75116 Paris, France