Privacy Policy

LDLC VR Studio is a simplified joint-stock company with a capital of 692,182 euros, registered in the Lyon Trade Register under number 802 162 321, whose registered office is located at 2 rue des Erables, 69 760 Limonest, represented by its president Mr. Laurent Villemonte de la Clergerie (hereinafter « LDLC VR Studio » or « the Company »).

LDLC VR Studio is a software development company specializing in the design and publishing of software. It notably developed a video game provisionally or definitively titled « TaVRn’s Takedown » (hereinafter the « Video Game »).

The User acknowledges having read and accepted without reservation these terms and conditions (hereinafter referred to as « the Privacy Policy »).

This Privacy Policy aims to inform users of (i) the Video Game, (ii) the mechanisms designed to secure access accounts, and (iii) the software tools associated with its use (collectively, the « LDLC VR Studio Services ») about the methods of collection, processing, and use of personal data by LDLC VR Studio, and their rights and obligations regarding the protection of personal data.

LDLC VR Studio is responsible for the collection of personal data, which is accessible to its parent company, Groupe LDLC, a public limited company with a management board, registered with the Lyon Trade and Companies Register under number 403 554 181 and having its registered office at 2 rue des Erables, 69760 Limonest, France.

By accessing or using the LDLC VR Studio Services, the User acknowledges having read and accepted this Privacy Policy.

Information for minors. Information transmitted by minors during the course of Most video game usage originates from connections made via the Meta or Steam platforms. It is important to read the terms and conditions under which they collect your personal data.

We retain the information you provide when you connect to the Meta or Steam platforms to communicate with you about your account, to track your purchases, to help you resolve security issues that may affect your video game use, and to send you useful information.

You have the right to access and correct your data. To exercise this right and obtain or delete your personal information, please write to us, with the help of your parents, at the email address dpo@groupe-ldlc.com or by mail: LDLC VR STUDIO, located at 2 rue des Erables, 69760 Limonest, France.

ARTICLE 1 : COLLECTED DATA

When using LDLC VR Studio Services, certain personal data may be requested.

The term « personal data » refers to any information that allows an individual to be identified directly or indirectly. LDLC VR Studio may also process anonymous data, aggregated or not, in order to analyze and produce statistics related to the habits, usage trends, and demographic data of customers as a group or as individuals. This anonymous data does not allow the identification of the customers to whom it relates. LDLC VR Studio reserves the right to share anonymous information, aggregated or not, with third parties.

The User is informed at the time of collection whether providing the requested personal data is optional or mandatory, as well as the potential consequences of not providing this data.

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LDLC VR Studio is responsible for the Video Game, its content, and the LDLC VR Studio Services, but access to the Video Game is exclusively via the platforms (i) Steam, operated by Valve, Inc., or (ii) Meta Store, operated by Meta Platforms Inc., Meta Platforms Ireland Limited, and their subsidiaries, which remain solely responsible for the data processing implemented for the purposes of their services.

LDLC VR Studio Support. For the best user experience, LDLC VR Studio has implemented a support system to ensure the correction of any anomalies in the operation of the Video Game and, more generally, the LDLC VR Studio

Services. To this end, the user may, via an online form, specify the subject of their request and, if applicable, certain information, including login credentials, name, surname, and email address. In some cases, LDLC VR Studio may ask the user to verify their identity by providing an official identity document.

In the event of a first request to the LDLC VR Studio support service, an email will be sent to validate access to online support.

ARTICLE 2 : PURPOSES & LEGAL BASIS

Personal data may be processed for various purposes and on different legal grounds:

2.1. Purposes. LDLC VR Studio only uses data necessary for the proper execution of the end-user license agreement enabling access to and use of the Video Game. Data is processed:

• to enable access to and use of the LDLC VR Studio Services;

• to enable purchases of products and services via partner platforms and to allow us to process, manage, and track your orders;

• for handling complaints and after-sales service;

• to provide assistance in the event of technical problems when using the LDLC VR Studio Services.

2.2. Lawfulness of processing. LDLC VR Studio only uses data based on its legitimate interests when these do not infringe upon the rights and freedoms of Users. The data is processed:

• to improve our LDLC VR Studio Services, including improving game performance and experience, customer experience, and bug management;

• to prevent and detect irregular behavior, particularly to combat payment fraud;

• for monitoring and tracking in-game behavior and ensuring compliance with the rules set forth in the End User License Agreement;

As part of our efforts to combat payment fraud and in-game cheating, automated decisions may be made based on interactions with LDLC VR Studio Services, partner platforms, and the data provided by the User. LDLC VR Studio may, in particular, restrict or suspend access to its services if this automated processing detects a user or activity that presents a risk of fraud or cheating.

2.3. Legal Obligations. LDLC VR Studio processes certain data when required by regulatory or legal provisions, particularly to comply with our accounting and tax obligations or when the law requires us to retain certain data.

ARTICLE 3 : PERSONAL DATA COMMUNICATION

LDLC VR Studio may use third-party service providers who will collect your personal data on behalf of LDLC VR Studio or with whom LDLC VR Studio will securely share certain data, in particular to ensure the completion of tasks necessary for order fulfillment, product delivery, payment processing, customer relationship management, combating in-game cheating, and combating payment fraud.

These service providers may be located outside the European Union. LDLC VR Studio has taken all necessary precautions to ensure a sufficient level of protection for your personal information by framing these transfers with the standard data protection clauses established by the European Commission.

LDLC VR Studio may also disclose certain personal data to the competent authorities, upon their request, in the context of legal proceedings, investigations, requests for information from the authorities, or to comply with other legal obligations.

ARTICLE 4. USER’S RIGHTS

Unless otherwise stipulated, any User may freely exercise the rights provided for in this article directly with LDLC VR STUDIO by email at dpo@groupe-ldlc.com or by mail to LDLC VR STUDIO’s registered office.

In the interest of confidentiality and the protection of personal data, LDLC VR Studio is required to verify the identity of the person making requests to exercise rights, in particular by requesting copies of official identity documents signed by the individual concerned.

Requests are processed as quickly as possible and in accordance with applicable legal provisions.

Right of access and right to data portability. The User has the right to obtain confirmation as to whether or not personal data concerning them is being processed by LDLC VR Studio and, where that is the case, access to said data and information relating to its processing.

Right to rectification. The User has the right to obtain the rectification of any inaccurate or incomplete personal data concerning them.

Right to erasure. Personal data is retained for as long as necessary to fulfill the purposes set out herein, in accordance with applicable law and subject to the exercise of the rights to erasure provided for herein.

The User may request the deletion of their personal data. However, LDLC VR Studio may retain certain data to protect its legitimate interests, such as the detection and prevention of fraud, as well as data necessary for the establishment, exercise, or defense of legal claims.

Right to restriction of processing. The User has the right to obtain restriction of the processing of their data, under limited circumstances:

(i) when the User contests the accuracy of their data;

(ii) when the processing is unlawful and the User has requested the restriction of its use instead of its erasure;

(iii) when LDLC VR Studio no longer needs your data for the purposes of the processing but it is still required for the establishment, exercise, or defense of legal claims;

(iv) when the User has objected to the processing pursuant to Article 9.5, pending verification of whether the legitimate grounds pursued by LDLC VR Studio override its own.

Right to object: The data subject may, at any time, on grounds relating to their particular situation, object to the processing of their personal data when such processing is based on a legitimate interest. If this right is exercised, LDLC VR Studio will no longer process the data in question, unless it can demonstrate compelling legitimate grounds for the processing which override the interests, rights and freedoms of the data subject, or for the establishment, exercise or defence of legal claims.

ARTICLE 5 : SECURITY

LDLC VR Studio implements appropriate technical and organizational measures, considering the nature of the data and the risks involved in its processing, to ensure a high level of data security and, in particular, to prevent data from being altered, damaged, or accessed by unauthorized third parties. LDLC VR Studio reserves the right to take legal action against any person attempting to access personal information that does not concern them.

ARTICLE 6 : UPDATES & HYPERLINKS

6.1. Updates. Should LDLC VR Studio subsequently implement personal data processing (e.g., account creation, addition of online features, individualized statistical tracking), this policy will be updated prior to implementation to inform users of the new purposes, the categories of data concerned, and their rights. The updated version of the privacy policy will always be accessible from the Studio’s official page or the game’s page on partner platforms.

6.2. Hyperlinks & Third-Party Sites. Hyperlinks on the LDLC VR Studio Services may lead to third-party sites and content over which LDLC VR Studio has no control. These third-party sites may have privacy policies that differ

from this one; users should always review the privacy policy of each such site. In any event, LDLC VR Studio cannot be held liable if the content of this or these sites violates applicable laws and regulations or this Privacy Policy.

ARTICLE 7 : QUESTIONS & COMPLAINTS

Within the limits of applicable regulations, data subjects have the right to access, rectify, and erase their personal data, the right to restrict processing, the right to object to processing, and the right to data portability. They also have the right to provide LDLC VR Studio with specific instructions regarding the fate of their data after their death. To exercise these rights, requests should be sent to:

· by post to the following adress : LDLC VR STUDIO – DPO 2 rue des Erables, 69 760 Limonest ;

· by email : dpo@groupe-ldlc.com.

They can also lodge a complaint with the Data Protection Authority if they are not satisfied with the response provided.

LDLC VR Studio has appointed a Data Protection Officer who can be contacted at the following address: Data Protection Officer of LDLC VR Studio – 2 rue des Erables, 69760 Limonest, France.