Sulkyland Privacy Policy

1. Data Controller

The data controller for personal data is:

For any questions regarding your personal data or to exercise your rights, you can use the contact form accessible via the Sulkyland menus.

Daniel Fichter is the representative of Dafilog and the point of contact for questions regarding personal data protection.

2. Data We Process

Depending on how you use Sulkyland, we may process the following categories of data.

Account creation and management data

• your username;
• your email address;
• your internal Sulkyland ID;
• the information necessary to authenticate and secure your account.

When you use a third-party service to log in to Sulkyland, we may receive the username provided by that service as well as the information you have authorized that service to share with us.

Data related to game usage

We record the information necessary for the operation of Sulkyland, including:

• your progress and actions within the game;
• information regarding your horses, stables, races, rankings, and actions taken;
• dates and times of login;
• any penalties, restrictions, or moderation actions;
• content you post in areas accessible to other players;
• messages and requests you send to support.

Certain information associated with your username, your activity, or your results may be visible to other players when this is part of the game’s normal operation.

Technical and Security Data

We may process:

• your IP address;
• information about your browser, operating system, and device;
• connection logs and technical events;
• information necessary to detect errors, abuse, intrusions, multiple accounts, or fraudulent behavior.

Purchase-related data

When you make a purchase on Sulkyland, we may receive and store:

• the date and amount of the transaction;
• the product or service purchased;
• the payment method used;
• the transaction ID and status;
• the information necessary for invoicing and accounting purposes.

Full banking information is processed directly by our payment service providers and is not stored by Dafilog.

3. Purposes and Legal Bases for Data Processing

Provision and Management of Sulkyland

We use your data to create and manage your account, authenticate you, save your progress, enable your participation in the game, and provide the requested features.

This processing is necessary for the performance of the contract entered into with you when you create and use your account.

Management of Purchases and Payments

We use transaction information to process your purchases, credit your account, track payments, and manage any claims.

This processing is based on the performance of the contract and, for accounting and tax data, on Dafilog’s legal obligations.

User Support

We use the information you provide to answer your questions, resolve technical issues, and handle your complaints.

This processing is based on the performance of the contract or on Dafilog’s legitimate interest in providing support and ensuring the proper functioning of its service.

Security and Prevention of Abuse

We may analyze connections andaccount activity to secure Sulkyland, detect fraudulent behavior, prevent intrusions, combat prohibited multiple accounts, and enforce the rules of the game.

This processing is based on Dafilog’s legitimate interest in protecting the service, its users, and its business operations.

Service Improvement

We may use technical data and internal statistics to detect errors, understand how the service works, and improve Sulkyland.

This processing is carried out in Dafilog’s legitimate interest in maintaining and improving its service.

Sulkyland does not use Google Analytics and does not use its users’ personal data for personalized advertising purposes.

4. Mandatory Nature of Data

The information marked as mandatory when creating an account is required to use Sulkyland.

If you do not provide this information, we will not be able to create your account or provide certain features.

Optional data is identified as such when requested.

5. Recipients of Data

Your data may be accessed, within the scope of their duties, by:

• authorized personnel within Dafilog;
• service providers responsible for hosting, maintenance, security, or sending emails;
• external internet service providers, when you choose to use them;
• payment service providers when you make a purchase;
• administrative or judicial authorities when required by law.

These service providers may only use the data to the extent necessary to fulfill their duties or in accordance with their own legal obligations.

Dafilog does not sell its users’ personal data.

6. Data Transfers Outside the European Economic Area

Certain technical service providers, internet service providers, or payment service providers may process data outside the European Economic Area.

When such transfers occur, Dafilog ensures that they are subject to the safeguards provided for by applicable regulations.

7. Retention Period

We retain your data only for as long as necessary for the purposes described in this policy.

• Data necessary for the operation of the account is retained for the duration of the account’s activity, and then for one year after its closure or lastuse.
• Technical and security logs are retained for one year.
• Data necessary for resolve a dispute may be retained until the applicable statute of limitations expires.
• Invoices and accounting documents are retained for the period required by regulation, generally ten years.

Upon expiration of these periods, the data is deleted or anonymized.

8. Cookies and Other Trackers

Sulkyland uses only cookies and similar technologies that are necessary for its operation or for providing the features requested by the user.

In particular, these cookies may allow:

• maintaining your login to your account;
• secure your session;
• save your technical preferences;
• provide the features you request;
• to remember your cookie preferences, when necessary.

Cookies that are strictly necessary for Sulkyland to function do not require your consent.

Cookies may also be set by an internet service provider or a payment service provider when you choose to use their service. Their use is then subject to that provider’s privacy policy.

9. Your Rights

Under the terms of applicable regulations, you have the following rights:

• the right to access your personal data;
• the right to request the correction of your personal data;
• the right to request the erasure of your personal data;
• the right to request the restriction of its use;
• the right to object to processing based on legitimate interests;
• the right to data portability for the data you have provided, where applicable;
• the right to withdraw your consent at any time for processing based on consent.

Withdrawal of consent does not affect the lawfulness of processing carried out prior to such withdrawal.

The right to erasure is not absolute. In particular, certain information may be retained to comply with a legal obligation, to defend Dafilog in legal proceedings, or to prevent fraud.

You can exercise your rights using the Sulkyland contact form.

We will respond as soon as possible and, in principle, within a maximum of one month. A reasonable verification of your identity may berequired in case of doubt.

You may also file a complaint with the French Data Protection Authority (CNIL): www.cnil.fr .

10. Minors

Sulkyland is accessible to individuals who are at least 13 years old.

Minors must use Sulkyland with the permission of their legal guardian and comply with the rules set forth in the Terms of Use.

Purchases made by a minor must be authorized by their legal guardian.

When data processing is based on consent and theuser is under 15 years of age, the consent of the holder of parental authority is also required under the conditions set forth by French law.

11. Account Deletion

You can request the deletion of your account and the personal data associated with it via the Sulkyland contact form.

Deleting your account does not necessarily result in the immediate deletion of all information. Certain data may beretained when necessary to comply with a legal obligation, prevent fraud, resolve a dispute, or defend Dafilog’s rights.

Content posted in the game’s community areas may be anonymized rather than deleted when it is necessary to understanding the exchanges in which other users have participated.

12. Security

Dafilog implementstechnical and organizational measures designed to protect personal data against loss, alteration, disclosure, and unauthorized access.

These measures include, in particular, mechanisms foraccess control, secure connections, data backup, and service monitoring, tailored to the nature of the data and the identified risks.

Since no IT system can guarantee absolute security, Dafilog regularly reviews its protective measures.

13. Changes to the Privacy Policy

This policy may be amended to reflect changes in Sulkyland, its service providers, or applicable regulations.

In the event of a substantial change regarding the use of your data, users will be notified by an appropriate means, such as within the game or via email.

The date of the last update appears at the beginning of this policy.