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Le propriétaire et éditeur de ce site web est la société de droit français Swasa
SWASA SAS, Société par Actions Simplifiée au capital de 5320€
ayant son siège social au 22 villa de Lourcine à Paris (75014) FRANCE,
immatriculée sous le numéro 751-213-182 RCS PARIS
N° TVA FR49751213182
Téléphone : +33.(0) 1 44 88 57 73
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La directrice de publication est : Elsa PRIETO

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Politique de confidentialité

Last updated: October 8th, 2014

SWASA S.A.S Privacy Policy

Swasa S.A.S. (“Swasa,” “we,” or “us”) welcomes you to and any and all applications or mobile applications offered by Swasa S.A.S. SWASA S.A.S (“Swasa”), its parent and its subsidiaries respect the privacy rights of our users and are committed to protecting the information collected through its online products, online services and websites, including, but not limited to, “Pili Pop” mobile applications and Pili Pop website (together “Services”). Swasa has adopted this privacy policy (“Privacy Policy”) to explain how Swasa collects, stores, and uses the information collected in connection with Swasa’s Services.


Non-personal data

For purposes of this Privacy Policy, “non-personal data” means information that does not directly identify you. Additionally, non-personal data means “aggregate” and “de-personalized” information, which is data Swasa collects about the use of Swasa Services, from which any personally identifiable data has been removed.
Swasa may is using tools or third party analytical software to automatically collect and use certain non-personal data that does not directly enable Swasa to identify you. The software Swasa is currently using is Flurry Analytics which is owned by Yahoo, and their Privacy Policy can be found here: . The types of non-personal data Swasa may collect and use include, but are not limited to: (i) device properties, including, but not limited to unique device identifier or other device identifier (“UDID”); (ii) device software platform and firmware; (iii) mobile phone carrier; (iv) game score and achievements; (v) other non-personal data as reasonably required by Swasa to enhance the Services and other Swasa products and services. Swasa may use and disclose to Swasa’s partners and contractors the collected non-personal data for purposes of analyzing usage of the Services, managing and providing the Services and to further develop the Services and other Swasa services and products.


We do not allow advertising companies to collect data through our service for ad targeting.

Personal Data

For purposes of this Privacy Policy, “personal data” means personally identifiable information that specifically identifies you as an individual. Likely situations when you make personal data available to Swasa include, but are not limited to: (i) registration for Services, contests and special events; (ii) accessing Services using a third party ID, such as social networking sites or gaming services; (iii) subscribing to newsletters; (iv) requesting technical support; and (v) otherwise through use of Swasa Services where personal data is required for use and/or participation.

The types of personal data may vary depending on the type of activity you are engaged in. The personal data Swasa may collect, process and use may include, but are not limited to the child’s first name, child’s birth date and parent’s e-mail address. Swasa may use collected personal data for purposes of analyzing usage of the Services, providing customer and technical support, managing and providing Services and to further develop the Services and other Swasa services and products. Swasa may combine non-personal data with personal data. Swasa may use your personal data to send messages to you with informative and/or commercial content about Swasa’s services and services Swasa thinks may be of interest to you, such as new features and services, special offers and updated information.

Disclosure and Transfer of Personal Data

Swasa collects and processes personal data on a voluntary basis and it is not in the business of selling your personal data to third parties. Personal data may, however, occasionally be disclosed in accordance with applicable legislation and this Privacy Policy. Additionally, Swasa may disclose personal data to its parent companies and its subsidiaries in accordance with this Privacy Policy. Swasa may use third party service providers such as e-mail service providers, shipping agents, data analyzers and business intelligence providers. Swasa has the right to share your personal data as necessary for the aforementioned third parties to provide their services for Swasa. Swasa is not liable for the acts and omissions of these third parties, except as provided by mandatory law. Swasa may disclose your personal data to third parties as required by law enforcement or other government officials in connection with an investigation of fraud, intellectual property infringements, or other activity that is illegal or may expose you or Swasa to legal liability. Swasa may also disclose your personal data to third parties when Swasa has a reason to believe that a disclosure is necessary to address potential or actual injury or interference with Swasa’s rights, property, operations, users or others who may be harmed or may suffer loss or damage, or Swasa believes that such disclosure is necessary to protect Swasa’s rights, combat fraud and/or comply with a judicial proceeding, court order, or legal process served on Swasa. To the extent permitted by applicable law, Swasa will make reasonable efforts to notify you of such disclosure through Swasa’s website or in another reasonable manner.

Data Retention and Correctness

Swasa retains the data collected pursuant to this Privacy Policy for the period necessary to fulfill the purposes outlined in this Privacy Policy unless a longer retention period is required or permitted by law. Thereafter if the collected data is no longer needed for purposes specified in this Privacy Policy, Swasa deletes all aforementioned data in its possession within a reasonable timeframe. Swasa does not verify the correctness of personal data. Swasa may still retain some of the data to the extent such retention is necessary to resolve disputes, enforce Swasa user agreements, and comply with technical and legal requirements and constraints related to the security, integrity and operation of Services.

Cookies, beacons and tracking

The Services may use “cookies” and other technologies such as pixel tags, clear GIFs and web beacons. Swasa treats information collected by cookies and similar technologies as non-personal data. E-mails and other electronic communications Swasa sends to you may contain code that enables Swasa to track your usage of the communication, including whether the communication was opened and/or what links were followed (if any). Swasa may combine that information to other information Swasa has about you and Swasa may use that information to improve the Services and/or provide customized communications to you.

Third Party Terms and Conditions

Please note that your access to and use of the Services may be subject to certain third party terms and conditions and privacy policies, including but not limited to application stores, mobile software platforms, online gaming platforms, social networking services and payment providers. You recognize and agree that Swasa is not liable for any such third party terms and conditions and their use of your personal data.


Swasa follows generally accepted industry standards and maintains reasonable safeguards to attempt to ensure the security, integrity and privacy of the information in Swasa’s possession. Only those persons with a need to process your personal data in connection with the fulfillment of their tasks in accordance with the purposes of this Privacy Policy and for the purposes of performing technical maintenance, have access to your personal data in Swasa’s possession. Personal data collected by Swasa is stored in secure operating environments that are not available to the public. However, no system can be 100% secure and there is the possibility that despite Swasa’s reasonable efforts, there could be unauthorized access to your personal data. By using the Services, you assume this risk.


Swasa is not responsible for any personal data you choose to make public.

Swasa takes children’s privacy seriously, and encourages parents and/or guardians to play an active role in their children’s online experience at all times. Swasa may store and/or transfer your personal data to its affiliates and partners in and outside of EU/EEA member states in accordance with mandatory legislation and this Privacy Policy. Swasa may disclose your personal data to third parties in connection with a corporate merger, consolidation, restructuring, the sale of substantially all of Swasa’s stock and/or assets or other corporate change, including, without limitation, during the course of any due diligence process provided, however, that this Privacy Policy shall continue to govern such personal data.


You may have the opportunity to follow links on the Site to other site that may be of interest to you. Swasa endeavors to only link to reputable organizations. Because other site may not be hosted or controlled by Swasa, we are not responsible for the privacy practices of those sites or the content provided thereon. Therefore, the privacy policies with respect to other site may differ from those applicable to the Site. We encourage you to review the privacy policies of each other site. This Privacy Policy only applies to information collected and maintained by Swasa.

Notice of Privacy Rights of French Residents

In accordance with section 2 in chapter 5 of the new French law dated August 06, 2004, concerning “the protection of individuals with regard to the processing of personal information”, you have a right to access, modify, rectify and delete data concerning you. In order to do so, please contact Swasa at Swasa will need sufficient information from you to establish your identity and to verify your access request, and also to assist us in handling your request. Requests will be processed as soon as possible. Please note that even if personal data is changed or deleted according to your request, Swasa may still retain some of your personal data to resolve disputes, enforce Swasa user agreement(s), and comply with technical and legal requirements and constraints related to the security, integrity and operation of Swasa Services.

Our privacy policy may change from time to time. If we make any material changes to our policies, we will place a prominent notice on our website or application. If the change materially affects registered users, we will send a notice to you by email, push notification or text.

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