Privacy PolicyPrivacy Policy

Privacy Policy

Version Date: [October 22], 2026

GEODE ("us", "we", or "our"), 6 rue Jean Piccandet 69290 Saint-Genis-Les-Ollières, France, operates the Dazzly mobile application (hereinafter referred to as the "Service"). In connection with the Service, GEODE is the Data Controller of your Personal Data.

This page informs you of our policies regarding the collection, use and disclosure of Personal Data when you use our Service.

Unless otherwise defined in this Privacy Policy, the terms used in this Privacy Policy have same meanings as in our Terms.

This Privacy Policy is made pursuant to Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data, and repealing Directive 95/46/EC (“General Data Protection Regulation” or “GDPR”) and French Law no. 78-17 of 6 January 1978 (“French Data Protection Act”).

Definitions

  • Account

    Account means a unique account created for you to access our Service or parts of our Service.

  • Service

    Service means our App and our Site.

  • Personal Data

    Personal Data means any information relating to an identified or identifiable natural person; an identifiable natural person is one who can be identified, directly or indirectly.

  • Usage Data

    Usage Data means data collected automatically either generated by the use of the Service or from the Service infrastructure itself (for example, the duration of a page visit, the type of mobile device you use, your mobile device unique ID, the IP address of your mobile device, your mobile operating system, the type of mobile Internet browser you use, unique device identifiers and other diagnostic data). Usage Date are also collected from the Community Features of the Service (such as, the dates and times you signed up, logged in and logged out, your interactions with Community Features and other Users (likes, shares, groups visited, content viewed, app opens) with the date and time of those actions, your gamification level and score, and engagement metrics calculated from your activity, performance metrics of the Community Features, your subscription status, record of your acceptance of the Terms).

  • Cookies

    Cookies are small files stored on your device (computer or mobile device).

  • Data Controller

    Data Controller means the natural or legal person, public authority, agency or other body which, alone or jointly with others, determines the purposes and means of the processing of personal data.

  • Data Processor

    Data Processor means a natural or legal person, public authority, agency or other body which processes Personal Data on behalf of the Data Controller.

    We may use the Services of various Data Processor.

  • Data Subject (or User)

    Data Subject (or User) means any living individual who is using our Service and whose Personal Data is processed by us. They are at least 18 years old and over.

  • User-Provided Data

    User-Provided Data means data that you submit to features of the Services such as prompts or other input data provided to the artificial intelligence features of the Service or data you submit by using Community Features of the Service (such as reactions, shares and answers to polls, and the technical data associated with them). Such data, to the extent that it is entered by the User, may either (i) directly constitute Personal Data or (ii) indirectly constitute Personal Data insofar as it is associated with the User’s Account.

Processing activities

Purposes of the processing Types of Personal Data processed Legal bases for the processing Retention period
Account creation, login to the Service and access to functionalities that are available to you as a registered User
Processing mandatory to use the Service. 		Login details (email address and password)
Personal information (first and last names)
If the User uses the Community Features: profile picture, username, description, and SSO identifier		 Performance of the contract with the User For the validity period of the Account
Provision of the Service
Processing mandatory to use the Service. 		Usage Data
User-Provided Data
Your settings
User ID (a unique identifier associated with your Account) and install ID (an identifier associated with your installation of the Service)		 Performance of the contract with the User For the validity period of the Account or 13 months after collection if the User use the Service without Account
Providing access to paid Service
Processing mandatory to use the paid Service. 		Application Store transaction data Performance of the contract with the User For the validity period of the Account plus 5 years in intermediate archiving
Improvement of the Service
Processing mandatory to use the Service. 		Usage Data
Content of optional surveys and feedback		 Legitimate interest to process data to improve the Service quality 13 months after collection
Handling and answering to your requests
Processing optional to use the Service. 		Email address
Personal information (first and last name)
Usage Data
Content of the request		 Performance of the contract with the User For the validity period of the Account plus 5 years in intermediate archiving or 5 years after collection if the User use the Service without Account
Content and profile moderation
Processing mandatory to use the Service. 		Email address
Personal information (first and last name, profile picture, username and description)
Usage Data
User-Provided Data
User ID and install ID
Content of the request		 Performance of the contract with the User
Legal obligation		 Information related to the moderation request are retain for the validity period of the Account plus 5 years in intermediate archiving
Moderated content or banned profiles are retain for 3 years after the moderation decision
Marketing (including news, special offers and general information related to our Service unless you have opted not to receive information)
Processing optional to use the Service. 		Email address
Personal information (first and last name)		 Legitimate interest to send marketing emails related to our Service For the duration of the User’s active Account plus 3 years or 3 years from the last contact with the User
Information about changes to our Service, interactions with other Users, and community or security updates
Processing optional to use the Service. 		Email address
Personal information (first and last name)		 Legitimate interest to send information emails or in app notification related to our Service For the validity period of the Account
Support
Processing mandatory to use the Service. 		Email address
Personal information (first and last name)
Usage Data
User ID and install ID		 Performance of the contract with the User For the validity period of the Account plus 5 years in intermediate archiving or 5 years after collection if the User use the Service without Account
Detection, prevention and addressing of technical issues
Processing mandatory to use the Service. 		Usage Data Legitimate interest in making our Service accessible and usable under appropriate conditions 13 months after collection
Tailoring the content displayed to you on the Community Features of the Service and suggesting relevant posts or features
Processing mandatory to use the Service. 		Usage Data
User-Provided Data
User ID		 Legitimate interest in making our Service relevant for Users 13 months after collection

Tracking & Cookies Data

We use cookies and similar tracking technologies to track the activity on our Service and we hold certain information.

You can instruct your browser to refuse all Cookies or to indicate when a Cookie is being sent. However, if you do not accept Cookies, you may not be able to use some portions of our Service.

Examples of Cookies we use:

  • Session Cookies. We use Session Cookies to operate our Service. Legal basis: legitimate interest to ensure the proper functioning and delivery of the Service.
  • Preference Cookies. We use Preference Cookies to remember your preferences and various settings. Legal basis: legitimate interest to customize and optimize the User’s experience.
  • Security Cookies. We use Security Cookies for security purposes. Legal basis: legitimate interest to ensure the security of the Service.
  • Advertising Cookies. Advertising Cookies are used to serve you with advertisements that may be relevant to your interests. Legal basis: your consent.

We retain tracking & Cookies Data for 13 months after collection.

Transfer of Personal Data

Personal Data is processed by us in European Union.

Personal Data may be transferred outside European Union based on adequacy decisions within the meaning of article 45 of the GDPR or subject to appropriate safeguards within the meaning of article 46 of the GDPR, such as standard contractual clauses adopted by the European Commission.

Personal Data is transferred to the United States in connection with the hosting services provided by Amazon Web Services Inc. (AWS). Such transfers are governed by the standard contractual clauses adopted by Commission Implementing Decision (EU) 2021/914 of 4 June 2021 on standard contractual clauses for the transfer of personal data to third countries pursuant to Regulation (EU) 2016/679 of the European Parliament and of the Council.

Retention Period

Personal Data are retained for the periods specified above according to the processing activities carried out.

Some Personal Data may be retained for an additional period necessary to comply with our legal or regulatory obligations or for the exercise of our rights in legal proceedings.

Beyond these periods, anonymized data may be retained for archiving or statistical purposes.

Community Features: Your community account may be deleted if you remain inactive for 3 years. Upon deletion of your community account: (i) access to the Community Features ends and your profile is no longer visible to other Users, (ii) your public interactions with the community are anonymised, (iii) data used for analytical or statistical purposes is anonymised, (iv) all other data is deleted. Deletion is carried out within 30 days of your request of community account deletion. Residual copies may remain in our automated backups no longer than 180 days.

Your Personal Data Protection Rights under the GDPR

If you wish to exercise your rights under the GDPR, please contact us at the email address below.

You have the right to access, rectify, erase, restrict, object to the processing of your Personal Data, data portability, withdrawal of consent, and to set directives regarding the fate of your Personal Data after death, under the conditions and limits provided by GDPR and the French Data Protection Act.

Some Personal Data can be directly modified by you through the Service. This may limit the relevance of certain rights, such as rectification or access, where data has been changed or deleted by you.

All requests will be processed promptly and in accordance with the applicable law. In some cases, personal data can only be deleted after a certain period imposed by applicable regulations and prescription rules. In such cases, we will retain the data until the permitted deletion date.

You are informed that in the event of refusal to provide personal data or exercise of your right to deletion or objection, we may have to suspend or terminate all or part of the Service.

Please note that we may ask you to verify your identity before responding to such requests. We can ask you to attach a copy of a valid official identity document, such as an identity card or passport, to support such request.

You have the right to complain to a data protection authority about our collection and use of your Personal Data.

Objection to receiving commercial communications

Any recipient of communications related to the promotion of our activities may unsubscribe at any time, even if they have previously expressed a different preference, by clicking on the unsubscribe link included in such communications or by sending a request to the contact details below.

Recipients of Personal Data

We may employ third party companies and individuals to facilitate our Service ("Service Providers"), provide the Service, perform Service-related services or assist us in analysing how our Service is used.

When we engage these Service Providers as Data Processors to carry out processing activities, we do so in accordance with Article 60 of the French Data Protection Act and Article 28 of the GDPR.

Analytics

We may use third-party Service Providers to monitor and analyse the use of our Service.

  • Firebase

    Firebase is analytics service provided by Google Inc.

    You may opt-out of certain Firebase features through your mobile device settings, such as your device advertising settings or by following the instructions provided by Google in their Privacy Policy: https://policies.google.com/privacy?hl=en

    We also encourage you to review the Google's policy for safeguarding your data: https://support.google.com/analytics/answer/6004245.

    For more information on what type of information Firebase collects, please visit the Google Privacy & Terms web https://policies.google.com/privacy?hl=en

  • Adjust

    Adjust is a mobile measurement and analytics service provided by Adjust GmbH, Germany. We use Adjust to measure app installations, attribute user acquisition campaigns, analyze in-app events and revenue, and evaluate the effectiveness of our advertising campaigns.

    For more information on how Adjust processes personal data, please visit its Privacy Policy: https://www.adjust.com/terms/privacy-policy/

  • GameAnalytics

    GameAnalytics is a game analytics service provided by GameAnalytics. We use GameAnalytics to analyze how users interact with our Service, measure gameplay activity and performance, and improve the user experience.

    For more information on how GameAnalytics processes personal data, please visit its Privacy Notice: https://www.gameanalytics.com/trust/privacy-notice

Advertising

We may use third-party Service Providers to show advertisements to you to help support and maintain our Service.

  • AdMob by Google

    AdMob by Google is provided by Google Inc.

    You can opt-out from the AdMob by Google service by following the instructions described by Google: https://support.google.com/ads/answer/2662922?hl=en

    For more information on how Google uses the collected information, please visit the "How Google uses data when use our partners' sites or app" page: http://www.google.com/policies/privacy/partners/ or visit the Privacy Policy of http://www.google.com/policies/privacy/

  • InMobi

    InMobi is provided by InMobi Pte Ltd.

    For more information on the privacy practices and policies of InMobi, please visit the InMobi Privacy Policy: http://www.inmobi.com/privacy-policy/

  • AppLovin

    AppLovin is provided by the AppLovin Corporation.

    For more information about AppLovin, please visit the Privacy Policy page of AppLovin: https://legal.applovin.com/privacy/

  • Vungle

    Vungle is provided by Vungle Inc.

    For more information about Vungle, please visit Vungle Privacy Policy: http://vungle.com/privacy/

  • Unity Ads

    Unity Ads is provided by Unity Technologies.

    For more information about Unity Technologies, please visit Unity Technologies Privacy Policy: https://unity3d.com/legal/privacy-policy

  • Mintegral

    Mintegral is a mobile advertising platform operated by Mintegral. It may be used to display advertisements within our Service.

    For more information on how Mintegral processes personal data, please visit its Privacy Policy: https://www.mintegral.com/en/privacy

  • Pangle (TikTok Ad Network)

    Pangle, also known as TikTok Ad Network, is a mobile advertising platform operated by entities of the TikTok group. It may be used to display advertisements within our Service.

    For more information on how Pangle processes personal data, including the applicable privacy policies depending on your country of residence, please visit: https://www.pangleglobal.com/terms/28179

  • DT Exchange (formerly Fyber)

    DT Exchange is a mobile advertising and monetization platform operated by Digital Turbine. It may be used to display advertisements within our Service.

    For more information about Digital Turbine and its privacy practices, please visit: https://www.digitalturbine.com/legal

  • Meta Audience Network

    Meta Audience Network is a mobile advertising service provided by Meta. It may be used to display advertisements within our Service.

    For more information on Meta's data processing practices, please visit its Privacy Policy: https://www.facebook.com/privacy/policy/

Behavioral Remarketing

GEODE uses remarketing services to advertise on third party websites to you after you visited our Service. We and our vendors use Cookies to inform, optimise and serve ads based on your past visits to our Service.

Payments

We may provide paid products and/or services within the Service. In that case, we use third-party Service Providers for payment processing (e.g. payment processors).We will not store or collect your payment card details. That information is provided directly to our third-party payment processors whose use of your personal information is governed by their Privacy Policy.

The payment processors we work with are:

App features

We use Service Providers to provide you with the artificial intelligence features and Community Features available with the Service.

  • Open AI

    Artificial intelligence features available with the Service are provided by OpenAI Ireland Ltd or any other company of the OpenAI group (“OpenAI”). The data you submit through the artificial intelligence features is transferred to OpenAI to enable the provision of these features. OpenAI acts either as a Data Processor or as an independent Data Controller when OpenAI determines the purposes of the processing it carries out.

    The OpenAI Privacy Policy can be viewed at https://openai.com/fr-FR/policies/privacy-policy/

Changes to This Privacy Policy

We may update our Privacy Policy from time to time. We will notify you of any changes by posting the new Privacy Policy on this page.

We will let you know via email and/or a prominent notice on our Service, prior to the change becoming effective and update the "Version Date" at the top of this Privacy Policy.

You are advised to review this Privacy Policy periodically for any changes. Changes to this Privacy Policy are effective when they are posted on this page.

Contact Us

If you have any questions about this Privacy Policy, please contact us: