Privacy Policy — DLCompare

Last updated: [DATE — to be set at publication]

1. Who we are

DLCompare (the "Service", "Website") is operated by SAS Digital Services, 24 rue René Boulanger, 75010 Paris, France ("DLCompare", "we", "us", "our").

DLCompare is a price-comparison website for video games, DLCs, prepaid cards, software, hardware, consoles and accessories. We do not sell any of these products ourselves: we compare offers from third-party retailers and redirect you to the retailer you choose, where the purchase and payment take place.

For any question about this Policy or your personal data, contact us via the Contact page or our community support on Discord.

2. What data we collect

2.1 Data you provide to us

• Account data: email address, username/pseudonym, and — if you log in via a social provider — the data that provider shares with us (see section 4).
• Price Alerts: the products you track and the email address associated with the alerts.
• Rewards Program (dLCoins): your account activity, participation, points and leaderboard ranking.
• Reviews, comments and community content: pseudonym, published content and its date.
• Support requests: identity, email address and the content of your request (order issues, partnership requests, etc.).
• Newsletter: your email address and your consent.

2.2 Data collected automatically

• Usage data: IP address, approximate geographic region/country, browser type and version, pages visited, time and date of the visit, time spent, device identifiers and other diagnostic data.
• Approximate location: we use your IP address/country to show you only the offers that are valid and activatable in your region — this is a core feature of the comparison service.

2.3 Data from third-party login providers

When you create an account or log in via Google, Facebook (Meta) or X (Twitter), we receive the data those providers share with us (typically name and email address). You can disconnect a social login and remove the associated data from your account settings (My Information → Social Media → Disconnect).

3. Why we use your data

Note: Durations marked "[to be defined]" must be fixed with a defined period or objective criterion before publication — "as long as necessary" is not specific enough.

4. DLCompare account & social login

You can create an account directly with DLCompare or use one of the following login providers:

• Google (Google LLC / Google Ireland Ltd) — authentication provider
• Facebook / Meta (Meta Platforms Ireland Ltd) — authentication provider
• X / Twitter (X Corp) — authentication provider

When you use a social login, the provider authenticates you and shares with us the data listed in section 2.3. The provider is a separate data controller for the processing it performs. See each provider's own privacy policy for details.

5. Price Alerts

Price Alerts let you track a product and receive a notification when its price changes. We process: the tracked product, your account and your email address. Alerts are kept until you delete the alert or close your account.

6. Rewards Program (dLCoins)

The Rewards Program rewards participation on DLCompare. We process your account, activity, points and leaderboard ranking to operate the program. [Retention and any third-party processor to be defined.]

7. Reviews, comments and community features

When you post a review or comment, we process your pseudonym, the published content and its date. Published content is visible to other users. [Moderation and retention to be defined.]

8. Newsletter and communications

If you subscribe to the newsletter, we process your email address on the basis of your consent. You can unsubscribe at any time via the link in each email. [Email-sending provider to be named here — to be confirmed.]

9. Affiliate links and partner retailers

DLCompare compares offers from third-party retailers. Some outgoing links are affiliate links: DLCompare may receive a commission when you click an offer and/or make a purchase at the retailer.

When you click an offer, DLCompare and/or its affiliate partners may process technical information associated with the referral — such as the selected offer, the retailer, a timestamp, a referral identifier and limited device or network information. This data is used to attribute transactions, calculate commissions, prevent fraud and measure the performance of our partnerships.

The purchase itself, the payment and the retailer's processing of your order are governed by the retailer's own terms and privacy policy. DLCompare never collects your payment details.

[Insert the actual list of affiliate networks / retailers used — to be confirmed.]

10. Analytics and cookies

We use analytics and tracking technologies to measure and improve the Service:

• Google Analytics 4 (Google) — audience measurement
• Google Universal Analytics (legacy) — audience measurement
• Google Tag Manager (Google) — tag management container
• Cloudflare — content delivery, security and traffic analytics (Cloudflare Insights)
• Meta / Facebook Pixel — [scope to be confirmed: site-wide or specific pages]

Please see our Cookie Policy for the full list of cookies, their purposes, durations and the consent required.

11. Our service providers

We may share data with the following categories of processors:

• Google (Analytics, Tag Manager, and Google as a login provider)
• Meta (Facebook login and Pixel)
• X / Twitter (login provider)
• Cloudflare (CDN, security, DDoS protection)
• Email-sending provider [to be confirmed]
• Analytics / UX tools [to be confirmed — e.g. Hotjar, if still active]
• Hosting / infrastructure providers

Each provider processes data on our behalf under a data-processing agreement, or as an independent controller for its own purposes (e.g. social login).

12. International data transfers

Some of our service providers (e.g. Google, Meta, Cloudflare) may process data outside the European Economic Area. When this happens, transfers are covered by appropriate safeguards such as the European Commission's Standard Contractual Clauses or an adequacy decision. Contact us for a copy of the relevant safeguards.

13. Data retention

We keep personal data only for as long as necessary for the purposes in section 3. The specific retention periods are listed in the table and will be completed before publication.

14. Your GDPR rights

Under the GDPR (and applicable equivalents such as the UK GDPR), you have the right to:

• Access your personal data
• Rectify inaccurate data
• Erase your data ("right to be forgotten")
• Restrict processing
• Object to processing based on legitimate interest
• Data portability
• Withdraw consent at any time (for consent-based processing)
• Lodge a complaint with a supervisory authority — in France, the CNIL (Commission Nationale de l'Informatique et des Libertés)

15. How to exercise your rights

To exercise any of these rights, contact us via the Contact page. We may ask you to verify your identity. We respond within one month (extendable by two months for complex requests).

16. Children

The Service is not directed to children under the age of 16. We do not knowingly collect personal data from children. If you believe a child has provided us personal data, contact us and we will delete it.

17. Security

We implement appropriate technical and organisational measures (encryption, access control, CDN/WAF protection via Cloudflare) to protect your data. No method of transmission over the internet is 100% secure.

18. Changes to this policy

We may update this Policy. We will post the new version on this page and update the "Last updated" date. For material changes we may notify you by email or with a notice on the Service.

19. Contact / CNIL

• Contact: DLCompare contact page — or Discord
• Company: SAS Digital Services, 24 rue René Boulanger, 75010 Paris, France
• Supervisory authority: CNIL — www.cnil.fr

This policy is provided as a working draft for review by your legal counsel / DPO before publication.