Privacy Policy

1. Identity of the data controller

The data controller is Gamevestor, a simplified joint-stock company under French law, registered in the Annecy Trade and Companies Register under number 938 196 714, whose registered office is located at 5 rue de l’Industrie, 74000 Annecy, France.

Contact email for any questions relating to personal data: [email protected].

2. Persons concerned by the processing

The personal data processing operations implemented by Gamevestor concern the following categories of persons:

• site visitors;
• contributors (donations / contributions);
• investors (natural and legal persons);
• project owners / studios (legal persons);
• legal representatives, corporate officers and ultimate beneficial owners of legal persons.

3. Nature of the personal data collected

3.1 Data collected concerning natural persons

Depending on the features used, Gamevestor may collect in particular:

• first and last name;
• date and place of birth;
• nationality;
• postal address;
• email address;
• phone number;
• login credentials and password (encrypted);
• proof of identity (national identity card, passport);
• proof of address;
• bank details (RIB, IBAN, BIC);
• tax information and tax preferences;
• responses to regulatory questionnaires (investor profile, financial knowledge, ability to bear losses);
• amounts invested or contributed and history of operations;
• contractual documents signed electronically;
• communications exchanged with Gamevestor;
• IP address, connection logs and browsing data.

3.2 Data collected concerning legal persons

For project owners and legal entity investors, the data collected may include:

• company name;
• legal form;
• SIREN / SIRET number;
• address of the registered office;
• articles of association;
• Kbis extract;
• declaration of ultimate beneficial owners;
• identity and contact details of legal representatives;
• identity documents of corporate officers and beneficial owners;
• valid professional bank details opened in the name of the legal person;
• financial, legal and operational documents necessary for the analysis and monitoring of projects.

4. Purposes of processing and legal grounds

Personal data is collected and processed for the following purposes:

• creation and management of user accounts;
• access and use of the platform's services;
• management of contributions and investments;
• analysis, selection and monitoring of funded projects;
• compliance with the legal and regulatory obligations applicable to PSFPs, in particular regarding customer identity verification (Know Your Customer – KYC), verification of the identity of legal persons (Know Your Business – KYB), anti-money laundering and combating the financing of terrorism (AML-CFT) and anti-fraud;
• management of payments and payment accounts via approved providers;
• communication with users (notifications, contractual information);
• sending marketing communications subject to prior consent;
• improving the Platform and audience measurement;
• security of information systems.

5. Legal bases for processing

The legal bases applicable to the processing operations described above are as follows:

• the execution of a contract or pre-contractual measures;
• compliance with legal and regulatory obligations;
• Gamevestor's legitimate interest (security, fraud prevention, improvement of services);
• user consent, in particular for marketing communications and non-essential cookies.

6. Regulatory processing, controls and automated decisions

As part of its regulatory obligations, Gamevestor may be required to carry out automated processing, including profiling operations, in particular for:

• identity verification;
• risk profile assessment;
• prevention of money laundering and terrorist financing.

These processing operations may lead to decisions such as refusing access to certain services or projects, in accordance with applicable legal requirements.

7. Recipients of the data

Personal data is accessible only to authorized persons of Gamevestor and may be transmitted, within the limits of their respective duties, to the following recipients:

• Technical and hosting providers (in particular EasyCrowd, Cloudflare, Amazon Web Services (AWS), Heroku);
• Payment and financial services provider: Lemonway, acting as an independent data controller;
• Electronic signature provider: Yousign;
• Marketing emailing provider: Brevo;
• Project companies (SPVs) set up as part of the financing operations, in order to ensure the maintenance of bond registers, the management of financial flows and the monitoring of investor rights;
• Project owner studios, only for the data strictly necessary for the execution of the financed projects.

8. Publicly available data and non-public data

As part of the use of the Platform, certain information may be made accessible to other users or stakeholders of the funded projects, under strictly defined conditions.

8.1 Data that may be made accessible

• first name and first letter of the user's surname;
• pseudonym or public identifier;
• total amount invested or contributed to a project;
• investor or contributor status on a project.

8.2 Data never made public

• password and login credentials;
• identity documents and proofs (ID card, proof of address, KYC / KYB);
• bank details (IBAN, BIC);
• full postal address, email and telephone number;
• IP address and detailed connection data;
• private communications with Gamevestor;
• tax information and responses to regulatory questionnaires.

9. Business continuity and run-off management

In accordance with the regulations applicable to PSFPs, Gamevestor has set up a continuity and run-off management system aimed at ensuring the continued monitoring of financing operations until their term.

The purpose of this system is to guarantee, in the event of interruption or cessation of the platform's activity, the continued monitoring of financing operations until their term, in the interest of investors and project owners.

10. Retention periods

• account data: duration of the contractual relationship, then archiving for up to 5 years;
• regulatory and financial data: 5 to 10 years in accordance with legal obligations;
• data related to security and fraud prevention: up to 1 year;
• marketing data: 3 years from the last contact or withdrawal of consent;
• cookies: 13 months maximum.

11. Data security

Gamevestor implements appropriate technical and organizational measures to guarantee the security, integrity and confidentiality of personal data, in particular through the encryption of sensitive data, access limitation and secure hosting in Europe.

12. Cookies

The Platform uses cookies and trackers subject to user consent, in particular for audience measurement purposes (Google Analytics). Preferences can be modified at any time via the cookie manager.

13. Rights of individuals

In accordance with applicable regulations, users have the following rights: access, rectification, erasure, restriction, objection, portability and withdrawal of consent.

These rights can be exercised by contacting [email protected].

14. Changes to the policy

This Policy may be modified at any time to reflect legal, regulatory or operational changes. The version in force is the one published on the Platform.