Privacy

Personal Data Protection Policy for Users of the Ludiz Platform Operated by Skillfab

1. Preamble

At Skillfab, the confidentiality and protection of user data are a priority. In the interest of transparency, this policy aims to clearly explain how user data on the Ludiz platform is stored, processed, and protected.

Ludiz is a SaaS solution for creating game content, available to organizations and their beneficiaries. It consists of two distinct environments:

  • The User Platform: allowing players to access content and participate in courses.
  • The Publisher Platform: dedicated to administrators and publishers for the creation and management of game courses.

2. Connection Methods and Data Collection

Skillfab uses Supabase, which complies with GDPR regulations and implements advanced security measures.

User Platform Users

Users of the User Platform have the choice between two login modes: anonymous or non-anonymous, depending on the preferences set by the client organization.

Mode 1: Anonymous Use

In this mode, Ludiz operates completely anonymously at the request of the client organization.

  • How it works: A list of fictitious logins (generated email addresses and passwords) is provided to the client organization, which assigns them to users. Ludiz cannot associate these logins with specific individuals.

  • Data provided in anonymous mode:

-Fictitious user ID and password: generated and disconnected from any identifiable individual.

-Technical Data: anonymized IP address, browser type, operating system.

-Usage Data: interactions with the platform (paths followed, time spent, actions taken, scoring).

-Aggregated Statistics: aggregate data used for analytical purposes, not linked to an identifiable individual.

Mode 2: Non-Anonymous Use

In this mode, the client organization can request that Skillfab collect personally identifiable data to meet specific needs (e.g., personalization of courses, individualized tracking, detailed reporting).

  • How it works: The user logs in with their email address and a personal password. Their interactions are then associated with their account.

  • Data provided in non-anonymous mode:

-Personally identifiable data: first name, last name, email address, and any other information provided by the user or the client organization.

-Technical Data: IP address, browser type, operating system.

-Usage Data: interactions with the platform (courses followed, time spent, actions performed).

-Individual and Aggregated Statistics: data that may include nominal reports, depending on the client's request.

Publishers and Administrators of the Publisher Platform

Skillfab may process personal data relating to publisher and administrator accounts to enable it to manage the contractual relationship.

The processing carried out is based: (i) for most purposes on the performance of the contract (or on the legitimate interests of each Party when it concerns data of employees, representatives, and/or managers); (ii) for other purposes, on the legitimate interest of each Party, namely the proper management and monitoring of the contract; (iii) and, in certain cases, particularly for purposes related to accounting and the management of requests to exercise rights, on the compliance of each Party with its legal obligations.

The personal data processed in this context will be retained for the duration of the contractual relationship and, if the information is of administrative interest or if the Parties have a legal obligation to do so, for the applicable limitation period (in principle, 5 years). Data relating to requests to exercise rights are kept in an active database for the duration of their processing. They are archived for 5 years from the response to the request, except for data relating to the right to object, which is kept for 6 years.

The data collected and processed in this context will only be accessible to employees, representatives, and managers of the Parties who need access to it as part of their duties and may be disclosed to third-party service providers, acting as processors within the meaning of the General Data Protection Regulation ("GDPR"), to perform, in particular, hosting, database management, or IT maintenance and support services.

Under the terms of the GDPR, the Parties, their employees, representatives, and directors have the right to access, rectify, erase, and transfer their personal data, the right to restrict processing, and the right to object to the processing of their data. Each Party and/or its employees, representatives, and/or directors also have the right to provide the other Party with specific instructions regarding the fate of their personal data after their death. Finally, when it concerns the basis for processing, the Parties, their employees, representatives, and directors have the right to withdraw their consent. To exercise these rights, the Parties and/or their employees, representatives, and directors may submit a request to SKILLFAB by email to contact@ludiz.com.

Finally, each Party and/or its employees, representatives, and/or directors may file a complaint with the French National Commission for Information Technology and Civil Liberties (CNIL) (online: https://www.cnil.fr/fr/plaintes or by post to the National Commission for Information Technology and Civil Liberties, Complaints Department, 3 Place de Fontenoy TSA 80715 75334 PARIS CEDEX.

3. Purposes and legal basis of processing

4. Data security and confidentiality

Skillfab implements strict security measures to protect data collected via the Ludiz platform, whether anonymous or not. These measures include:

  • Encryption of stored and transmitted data.
  • Access is restricted to authorized Skillfab personnel (access control through strong authentication).

Personal data in non-anonymous mode is processed in accordance with the GDPR and access is limited to authorized personnel.

5. User Rights

Anonymous Mode

Users have the right to be informed about the use of their data, although this data cannot be used to directly identify them.

Non-anonymous Mode

Users have the following rights regarding their personal data:

  • Right of access: to know what data is collected and processed.
  • Right of rectification: to correct inaccurate information.
  • Right to erasure: to request the deletion of their data.
  • Right to restriction of processing: to request a temporary restriction on the processing of their data.
  • Right to portability: to retrieve their data in a usable format.
  • Right to object: to object to the use of their data for certain purposes.

These rights can be exercised by contacting: 📧 contact@ludiz.com

Users can also file a complaint with the CNIL (French Data Protection Authority):🔗 www.cnil.fr/plaintes

6. Data retention period

7. Data Sharing and Subcontracting

Skillfab may share certain data with subcontractors (hosting, maintenance, IT support) strictly for the purpose of managing the Application. These partners are subject to contractual obligations regarding confidentiality and data security.

No user data is sold or shared with third parties for commercial purposes.

8. Policy Modifications

Skillfab reserves the right to modify this privacy policy to reflect legal and technical developments. Users will be informed of updates via the Platform.

9. Contact

For any questions regarding personal data protection, you can contact us: 📧 contact@ludiz.com