Privacy Policy

Last updated: March 4, 2026

1. Introduction

This Privacy Policy describes how your personal data is collected, used, stored, and protected when you use the SongTrivia application (hereinafter "the Application"), published by:

The Application is available on iOS, Android, and the Web (https://www.songtrivia2.io). By using the Application, you agree to the collection and use of your data as described in this Privacy Policy.

This Privacy Policy complies with the General Data Protection Regulation (EU) 2016/679 ("GDPR"), the French Data Protection Act (Loi Informatique et Libertes), the ePrivacy Directive, and the California Consumer Privacy Act ("CCPA") where applicable.

2. Data Controller

The data controller is:

3. Data We Collect

3.1 Data You Provide Directly

When you create an account or use the Application, we may collect:

3.2 Data Collected Automatically

When you use the Application, we may automatically collect:

3.3 Data Collected by Third-Party SDKs

The Application integrates third-party software development kits (SDKs) that may collect data independently:

3.4 Payment Data

Transactions are processed by Apple (App Store), Google (Google Play), or the applicable payment processor for web purchases. We do NOT collect or store your full credit card or payment information. We only receive transaction confirmations, subscription status, and purchase history.

4. Purposes and Legal Basis for Processing

We process your personal data for the following purposes:

| Purpose | Legal Basis | |---------|-------------| | Account creation and management | Performance of a contract (Art. 6(1)(b) GDPR) | | Providing the game service | Performance of a contract (Art. 6(1)(b) GDPR) | | Managing subscriptions and purchases | Performance of a contract (Art. 6(1)(b) GDPR) | | Displaying advertisements | Consent (Art. 6(1)(a) GDPR) | | Personalizing ad content | Consent (Art. 6(1)(a) GDPR) | | Analytics and service improvement | Legitimate interest (Art. 6(1)(f) GDPR) | | Preventing fraud and abuse | Legitimate interest (Art. 6(1)(f) GDPR) | | Responding to user requests and support | Performance of a contract (Art. 6(1)(b) GDPR) | | Compliance with legal obligations | Legal obligation (Art. 6(1)(c) GDPR) | | Sending promotional communications | Consent (Art. 6(1)(a) GDPR) |

For processing based on legitimate interest, we have conducted a balancing test to ensure our interests do not override your fundamental rights and freedoms. You may object to such processing at any time (see Section 9).

5. Data Retention

We retain your personal data only for as long as necessary to fulfill the purposes for which it was collected:

6. Data Sharing

We may share your personal data with the following categories of recipients:

6.1 Service Providers (Data Processors)

6.2 Advertising Partners

Playwire and its demand partners may act as independent data controllers for the data they collect through the Application. Playwire may share data with its demand partners for the purpose of delivering targeted advertising. Please refer to Playwire's privacy policy for details on their data practices and the list of their demand partners.

6.3 Legal Requirements

We may disclose your data if required by law, court order, or governmental authority, or if disclosure is necessary to protect our rights, property, or safety, or the rights, property, or safety of others.

6.4 Business Transfers

In the event of a merger, acquisition, or sale of assets, your data may be transferred to the acquiring entity. You will be notified of any such transfer.

We do NOT sell your personal data to third parties.

7. Advertising and Tracking

7.1

The Application displays advertisements provided by Playwire and its demand partners. These advertising networks may use advertising identifiers, device information, and similar technologies to collect information about your activity within the Application and across other apps and websites, in order to display targeted advertisements.

7.2 Apple App Tracking Transparency (iOS)

On iOS (version 14.5 and later), the Application complies with Apple's App Tracking Transparency (ATT) framework. You will be prompted for your consent before any tracking across apps or websites occurs. If you deny tracking:

7.3 Google Advertising Controls (Android)

On Android, you can opt out of personalized advertising:

7.4 Web Cookies and Tracking

On the web (https://www.songtrivia2.io), we use cookies and similar technologies subject to your consent through our cookie consent banner. You can manage your cookie preferences at any time through the cookie settings accessible from the Application footer.

7.5 Do Not Track

The Application does not currently respond to "Do Not Track" browser signals. However, you can manage your tracking preferences through the mechanisms described above.

8. International Data Transfers

Your data may be transferred to, and processed in, countries outside the European Economic Area (EEA), in particular the United States, when using services from the following providers:

In such cases, we ensure that appropriate safeguards are in place, including:

You may request a copy of the safeguards in place by contacting us at julien@anthm.fr.

9. Your Rights

9.1 Rights Under GDPR (EU/EEA Users)

Under the GDPR and French data protection law, you have the following rights:

9.2 Rights Under CCPA (California Residents)

If you are a California resident, you have the following additional rights under the CCPA:

9.3 How to Exercise Your Rights

To exercise any of your rights, contact us at: julien@anthm.fr

You may also delete your account directly from the Application settings.

We will respond to your request within 30 days (GDPR) or 45 days (CCPA). We may ask for proof of identity before processing your request.

10. Data Security

We implement appropriate technical and organizational measures to protect your personal data against unauthorized access, alteration, disclosure, or destruction, including:

Despite our efforts, no method of transmission over the Internet or electronic storage is completely secure. We cannot guarantee absolute security of your data. In the event of a data breach affecting your personal data, we will notify you and the relevant supervisory authority as required by applicable law.

11. Children's Privacy

12. Cookies and Similar Technologies

The web version of the Application (https://www.songtrivia2.io) uses cookies and similar technologies (local storage, pixels). The mobile versions use SDK-based tracking technologies that function similarly to cookies.

Types of cookies and technologies used

Strictly Necessary:

Analytics (subject to consent):

Advertising (subject to consent):

Managing your preferences

In compliance with CNIL guidelines:

13. Apple and Google Platform Requirements

13.1 Apple App Store (App Privacy Details / "Nutrition Labels")

In compliance with Apple's requirements, we disclose the following data collection in our App Store listing:

Data linked to you:

Data not linked to you:

Data used to track you (subject to ATT consent):

13.2 Google Play (Data Safety Section)

In compliance with Google Play's Data Safety requirements:

Data collected:

Data shared with third parties:

Security practices:

14. Third-Party Links

The Application may contain links to third-party websites or services. We are not responsible for the privacy practices of these third parties. We encourage you to review their privacy policies before providing any personal data.

15. Changes to This Privacy Policy

We may update this Privacy Policy from time to time. We will notify you of material changes by:

The updated Privacy Policy will take effect on the date indicated at the top of the document. Your continued use of the Application after the effective date constitutes acceptance of the updated Privacy Policy. If you do not agree with the changes, you should stop using the Application and delete your account.

16. Contact

For any questions or requests regarding this Privacy Policy or your personal data, contact us at:

For complaints regarding data protection, you may also contact the CNIL: