Privacy Policy

Applicable from May 1st 2022

When browsing the website accessible at the URL address http://pamcha.com (hereinafter referred to as the "Website") and/or on the following applications:

  • Chase Snap
  • Temple Blast Adventures
  • Mine Blast Adventures

(hereinafter referred to as the "Applications") users (hereinafter referred to as the "Users") are required to provide personal data.

Consequently, this privacy policy is intended to inform Users about the conditions of use of their data as well as their rights.

The Website and the Applications comply with French and European standards relating to the protection of privacy and personal data and in particular French Law No. 78-17 of 6 January 1978 on information technology, files and freedoms, as amended by Law 2004-801 of 6 August 2004, and European Regulation 2016/679 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data (hereinafter referred to as the “GDPR”).

Clause 1: Data Controller

The data controller of personal data is Pamcha, a simplified joint-stock company (SASU) with a share capital of 10.000,00 euros, registered in the Villefranche sur Saone-Tarare Trade and Companies Register under number 891138489 and whose registered office is located at 48 impasse des sources 69480 Anse - France, which publishes the Website and the Applications (hereinafter referred to as "Pamcha").

Clause 2: Nature of the data collected

The data collected on the Website and/or the Applications are those enabling Pamcha to identify Users directly or indirectly.

This may include personal data such as surname, first name, pseudonym, email address, postal address, date of birth, photographs or connection data (such as IP address, ISP, continent, sub-continent, country, region and city of connection) and/or geolocation data (such as country and city of residence) and/or Website and/or Application browsing data such as cookies and/or social media account data (Facebook) if Users decide to associate them and use them for their use of the Website and/or Application.

Users who provide the personal data of a third party must confirm that they have the consent of this third party regarding the use by the Website and/or the Applications, the publication and/or dissemination on the Website and/or the Applications of the latter’s personal data, where applicable.

For Users’ information, Pamcha may also collect data relating to use of the Website and/or the Applications but not allowing the identification of Users. This may include game data, event dates/times (such as starting a game, purchasing, viewing ads) and phone characteristics: brand, model, OS, OS version and language.

Clause 3: Purposes of collection

The personal data collected on the Website and/or the Applications are used for the following purposes:

  • To allow Users to update their account on the Website and/or on the Applications;
  • To allow Users to use the Website and/or the Applications;  
  • To allow Pamcha to send newsletters and communications for commercial purposes to Users subject to the Users’ prior consent;
  • To enable Users to interact with other Users on the Website and/or the Applications through publications in the form of posts and/or comments;
  • To enable Users to use the services offered via the Website and/or the Applications, in particular to have access to the game;
  • If necessary, to allow Pamcha to contact Users;
  • To allow Pamcha to collect comments from Users;
  • To manage of the Website and/or the Applications, operations relating to Users, requests relating to Users’ rights (right of access, rectification, erasure, objection, limitation and portability), disagreements and disputes relating to use of the Website;
  • To improve and optimise the quality and experience of the Website and/or the Applications (such as analysis of how Users play and browse the Website and/or the Applications);
  • Statistics and performance of the Website and/or the Applications (assessment of the success of marketing and advertising launch campaigns, audience measurements);
  • In order to adapt the advertising that Users view on the Website and/or on the Applications;
  • To secure the Website and/or the Applications against fraud, to attempt to detect, avoid or trace any attempted malicious action or computer intrusion and to manage any malfunctions such as breakdowns, bugs and errors.

Furthermore, Pamcha may also use the data to fulfil, where applicable, its legal and/or regulatory obligations.

Clause 4: Time of collection

The data collected by Pamcha is freely communicated by Users. They may also be collected automatically when using the Website and/or the Applications, in particular when Users:

  • connect to the Website and/or download the Applications;
  • browse the pages of the Website and/or the Applications;
  • create an account on the Website and/or on the Applications;
  • issue a comment or a post from their account, as their geolocation data is automatically indicated;
  • subscribe to the electronic newsletter and/or commercial communications of Pamcha and its business partners;
  • send a request to Pamcha via the contact email address.

The Website and/or the Applications may also ask Facebook and/or Google to use data from its Users’ Facebook and/or Google accounts, particularly when Users choose not to create an account but to use their Facebook or Google account to connect to the Website and/or the Applications. For more information about these authorisations, Users may refer to the privacy policies of Facebook and/or Google.

Clause 5: Consent

The privacy policy is available on the Website and/or on the Applications in the corresponding section.

Users are systematically informed of the privacy policy when they connect to the Website and/or the Applications. The creation of an account implies Users’ express, full and complete acceptance of this privacy policy.

By ticking the box: "I have read the privacy policy", Users consent to their personal data being stored and processed by Pamcha and/or its partners.

If Users wish to withdraw their consent to the processing of their data, they may simply send a request to the following address: dpo@pamcha.com

Clause 6: Recipients of Personal Data

The recipients of the personal data collected on the Website and/or the Applications are first and foremost Pamcha.

Other recipients may have access to the personal data. Where applicable, this means subcontractors, resource providers in charge of the Website and/or the Applications (administration, marketing, legal, etc.) of Pamcha and external providers (technical service providers, access providers, data analysis platforms, communication agencies, payment services, fraud prevention and prevention services, etc.) of Pamcha. The list of recipients may be consulted at any time at Users’ request.

In the context of a change of control of Pamcha within the meaning of Article L.223-3 of the French Commercial Code, an acquisition, insolvency proceedings or a sale of the assets of Pamcha, the data collected by Pamcha may be transferred to third parties.

In addition, [Pamcha may be obliged to transmit the data collected to a third party in the event of receipt of a request from a judicial authority or any administrative authority authorised by law requesting the communication of this information in accordance with the legislative provisions in force. If this is required by law, Users’ consent shall be obtained or a possibility of refusal shall be provided for before any data is transmitted.

Clause 7: User rights

In accordance with French Law no. 78-17 of 6 January 1978 on information technology, files and freedoms, amended by Law 2004-801 of 6 August 2004 and European Regulation 2016/679 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data, Users have:

  • a right to access their personal data;
  • a right to rectification of their personal data;
  • a right to the erasure of their personal data;
  • a right to object to the processing of their personal data;
  • a right to restrict the processing of their data.
  • a right to data portability.

Users wishing to assert one of their rights may send their request by email or by post to the following addresses:
Postal address: 48 impasse des sources 69480 Anse - France
Email: dpo@pamcha.com

In order to exercise one of these rights, Users must send Pamcha the information necessary for their identification: surname, first name, email and possibly their postal address. Furthermore, pursuant to the regulations in force, their request must be signed, accompanied by a photocopy of an identity document bearing their signature, specify in detail the right they wish to implement as well as the address at which they wish to receive the response in the event of the implementation of one of the rights listed above.

Pamcha will then undertake to respond within a maximum of one (1) month following receipt of the User’s complete request.

Due to the complexity of the request and/or the number of requests, this period may be extended to two (2) months provided that Pamcha informs the User within one (1) month of receipt of the request of the reasons for the delay.

If Pamcha does not comply with the request made by the User, Pamcha shall inform the User no later than one (1) month of receipt of the request of the reasons for its inaction.

Pamcha informs Users of their right to lodge a complaint with the Commission Nationale Informatique et Libertés (CNIL) 3 place de Fontenoy TSA 80715 – 75334 Paris Cedex 07 – www.cnil.fr

Clause 8: International transfers

Pamcha hereby informs Users that their personal data may be transferred to countries that do not provide a sufficient and appropriate level of data protection. Where applicable, Pamcha undertakes to carry out transfers in accordance with current European standards, in particular by signing standard contractual clauses with the recipients of the data or by ensuring that the latter comply with binding corporate rules (BCR).

Clause 9: Retention period

Users’ personal data will not be stored beyond the time strictly necessary for the purposes pursued as set out in the privacy policy and in accordance with applicable laws, and in any event for a period not exceeding (2) two years.

Any deletion by Users of their account User will result in the deletion of all personal data relating to and linked to this account, without it being retained by Pamcha.

Notwithstanding the foregoing, personal data that Pamcha needs to retain as evidence, for legal or administrative purposes or in accordance with the legislation in force, may be retained for a longer period in accordance with said legal retention obligations.

As an exception to the foregoing, Users are informed that cookies are retained for a maximum of one (1) year after first being saved on the User’s device.

Clause 10: Links

Users may have access on the Website and/or in the Applications to various links directing them to third-party websites.

Pamcha will not be liable for the content of the websites referenced on the Website and/or on the Applications for links posted by advertisers and/or on the Pamcha pages of social networks, for information or content provided by third parties or the privacy policies of such third parties, which Users of the Website and/or the Applications may access.

Pamcha has no control over hypertext links and/or other promotional formats.

Consequently, Pamcha gives no guarantee concerning in particular:

  • the veracity, quality, completeness and exhaustive nature of the content of the listed websites;
  • difficulties in accessing and operating listed websites;

and it may not under any circumstances be held liable in the context of a dispute arising between a website listed on the Website and/or the Applications and/or on the pages of social networks and one of the Users in particular due to losses or damage suffered, as the operators of the listed websites are alone responsible for the content of their website.

This privacy policy does not govern third-party websites or third-party content accessed by Users of the Website and/or the Applications.

Clause 11: Cookies

When consulting the Website, cookies or other means of recording collected browsing data are used by Pamcha or by third-party service providers for the Website and/or the Applications, which are deposited on Users’ devices (computer, mobile phone or tablet).

11.1 Cookies required to operate the Website

The cookies used by Pamcha make it possible to identify Users, recognise their browser when they connect to the Website and/or the Applications, record their browsing preferences and adapt the presentation of the Website and/or the Applications to the display preferences of Users’ devices, for the sole purpose of providing the game to which Users have access. These cookies are essential for the proper functioning of the Website and/or the Applications and for Users’ navigation on the Website and/or the Applications.

The saving of a cookie remains subject to Users’ wishes. Users therefore have the possibility of configuring their navigation software to object, in whole or in part (in particular depending on the issuer) to the saving of these cookies, but Pamcha draws Users’ attention to the fact that their browsing experience may be affected as a result.

11.2 Cookies to improve the services of the Website and/or the Applications, analytical cookies and cookies for sharing information with third parties

Other cookies making it possible, for example, to improve the performance of the Website and/or the Applications, to measure its audience and activity, to detect navigation problems and to improve the Users’ experience or share information with social networks, may be deposited on Users’ devices only with their express consent collected via a cookie banner or prompt window.

Clause 12: Children

Pursuant to Article 8 of Regulation (EU) 2016/679 of 27 April 2016, a child may alone consent to the processing of personal data with regard to the direct provision of information society services from the age of fifteen. Where the child is under fifteen years of age, processing is only lawful if consent is given jointly by the child concerned and the holder(s) of parental authority over the child.

A child over the age of fifteen may alone consent to certain processing of personal data based on non-contractual “consent”. A child over the age of fifteen can thus legally decide alone to accept cookies to view a website, to opt for a public or private profile on a social network or to activate an optional geolocation feature on an application. However, in principle, the ordinary law of minority applies, and children’s actions fall under parental responsibility. Furthermore, under French law, children are in principle considered as legally incapable of entering into a contract. However, in recommendation No. 1 “regulate the capacity of children to act online” published by the CNIL on 9 June 2021, the latter considers that:

“subject to the discretionary assessment of the courts, it would be consistent for children, depending on their level of maturity and in any event above the age of 15, to be considered capable of entering into contracts that involve the processing of their data for the purposes of online services, such as signing up to a social network or an online gaming site, if and only if:

  • the services are suitable for a child audience;
  • the processing strictly complies with data protection rules as set out in the GDPR and the French Data Protection Act (e.g. minimisation of data collected, for a clearly-stated purpose, for a limited period of time and in a secure manner);
  • the child is given clear and appropriate information about how his or her data will be used and of his or her data protection and privacy rights, to ensure the child understands the meaning and scope of the commitment being made;
  • parents have the legal right to request deletion of their child's account if they consider it necessary to protect their child's best interests.”

Pamcha thus scrupulously ensures compliance with the personal data of child Users authorised to access the Website and/or the Applications in accordance with the GDPR, the recommendations published by the CNIL and the general terms and conditions of use of the Website and/or the Applications. In addition, persons holding parental authority over these children will naturally be able to exercise the rights provided for in Clause 7 above for their child, according to the procedure described.

Clause 13: Amendment of the Privacy Policy

Pamcha reserves the right to amend this privacy policy at any time, in particular to take account of any legal, case law, editorial, functional and/or technical changes. Where necessary, Pamcha shall inform Users and/or seek their agreement. Pamcha advises Users to regularly consult the page of the Website and/or the Applications containing the privacy policy to read any changes or updates made to the privacy policy.

Clause 14: Contact

For any question relating to this privacy policy or for any request relating to personal data, Users may contact Pamcha at the following address:
48 impasse des sources 69480 Anse ) France

Clause 15: Governing law

The privacy policy is subject to French law.

Version of may 1st 2022