Who is responsible for the processing of your data?

Technologies ESA Inc.

Address: 1250 Boulevard Rene-Levesque Ouest, Suite 2200 Montreal QC H3B 4W8, Canadá.

Contact Data Protection Office: [email protected]

How will we process your data?

This Privacy Policy (the “Privacy Policy”) describes the privacy practices for Technologies ESA Inc. (“Technologies ESA Inc.”, “our”, “us” or “we”). The purpose of this Privacy Policy is to inform you about the types of information we gather about you, including information gathered when you use games and related services, which include, without limitation, applications for mobile devices. Technologies ESA Inc. strives to help visitors and users of the Applications, Sites and Services protect their privacy while using our Applications, Sites and Services. By using the Applications, the Sites and the Services, you expressly consent to the use and disclosure of information as described in this Privacy Policy.

1.Information Collection

You generally are not required to provide information about yourself when you visit the Services. However, we may ask you for some or all of the following types of information when you register with our Services, sign up for contests or sweepstakes, participate in surveys, access various content or features, submit comments or content, use a send-to-a-friend feature, or directly contact us with questions or feedback:

Contact information, such as name, e-mail address and telephone number;

Unique identifiers, such as a user name or password;

Demographic information, such as gender;

Personal data such as subscriptions;

Real-time Geolocation information;

Background location access;

Communications preferences;

Search queries;

Comments and other information posted in our interactive online forums;

Correspondence and other information that you send to us; and

Additional information as otherwise described to you at the point of collection or pursuant to your consent.

Our Apps are intended to create a unique augmented reality user experience using facial recognition technologies. To make our Apps work well for You, We offer tools that apply filters and effects fitting the contours of Your face, modifying the size and shape of facial features and following facial movements. In order to enable these services, We have to distinguish patterns of shape and form that compose a digital image of a still or moving face.

We will ask for Your separate permissions to enable Your camera. If You change Your mind, You will be able to revoke the given permission any time afterward by changing settings on Your Device. However, please note that rejecting or switching off this permission might negatively affect the use of our Apps or even affect its full functionality.

We will request real-time geolocation permission. This will allow us to give you access to various functionalities of our applications to enjoy the best user experience, thus ensuring the correct functioning of all the features that our applications can offer you.

Whenever the user decides, he can reject (“do not allow”) the permission to access location within the settings of his device or select between different privacy options such as “Allow all the time”; “Allow only when using the app” or “always ask”.

We use TrueDepth API technologies (ARKit) to create AR effects within the App. The only use of this information is to provide valuable user features. None of the information collected by the TrueDepth API ever leaves our internal system. We do not share information with third parties, do not store or process in any other way the data which we accessed and used via TrueDepth API. For more information about TrueDepth API technologies, you may visit https://support.apple.com/en-us/HT208108.

Photos created by TrueDepth API are stored until the user decides to delete his account.

If you decide not to provide this information, it may limit our ability to provide some of the above content.

We also may collect certain information automatically when you visit the Services, including:

Your Internet Protocol (IP) address, which is the number automatically assigned to your computer whenever you access the Internet and that can sometimes be used to derive your general geographic area;

Your device type or mobile carrier;

Other unique identifiers, including mobile device identification numbers; and advertising identifiers (e.g., IDFA);

Your browser type and operating system;

Sites you visited before and after visiting the Services;

Pages you view and links you click on within the Services;

Information collected through cookies, web beacons, Local Shared Objects, and other technologies;

Information about your interactions with e-mail messages, such as the links clicked on and whether the messages were received, opened, or forwarded; and

Standard Server Log Information

2.Use of Information

We may use information that we collect through the Services for a variety of purposes and features, including to:

Provide you with the products, promotions, services, newsletters, service and app improvements, provide information you request and respond to correspondence that we receive from you;

Contact you via email and otherwise assist about your account;

Conduct analysis on fan behavior in order to better serve you with offers and content that is of interest to you;

Maintain or administer the Services, perform business analyses, or for other internal purposes to improve the quality of our business, the Services, and other products and services we offer;

Furthermore, the use of your information by Technologies ESA Inc. will allow you to publish stories, comments, photos, and other information posted in our interactive online features. As well as improved services like customization and personalization, including providing you with tailored advertising; and as otherwise described to you at the point of collection or pursuant to your consent.

We will also use background location access to enable you to check-in at the stadium or other locations to earn virtual points and coins. You can choose to allow the app to access your location all the time or only when using the app. If you enable background location access, the app can track your location even when it’s not in use, but we assure you that we only track your location data as required to provide you with the services you requested. This enables the app to send push notifications to you when you’re near a location where you can check-in. If you choose to authorize location access only when using the app, you can check-in when you’re within the radius of a particular location. We understand that location privacy is important, and we respect your privacy by not tracking your location data beyond what’s necessary to provide you with the requested services.

3.Sharing of Information

Limited members of Technologies ESA Inc. Marketing Team and IT departments, as well as the third party vendor that processes fan data on behalf of Technologies ESA Inc. may access and otherwise process personal information in connection with their job responsibilities or contractual obligations.

We are committed to maintaining your trust, and we want you to understand when and with whom we may share the information we collect. At times, as described below, we may share your personal information with others for the purposes described above:

Service Providers: We may share your information with service providers that perform certain functions or services on our behalf (such as to host the Services, fulfill orders, provide products and services, manage databases, perform analyses, provide customer service, or send communications for us). We may share information with third-parties, such as social networking platforms, so that they may send tailored communications on our behalf via their platforms. These companies are authorized to use your personal information only as necessary to provide these services to us.

Select Business Partners: With your prior permission, we may share your information with select business partners so that they can provide you with special offers, promotional materials, and other materials that may be of interest to you. For example, you may be presented with an opportunity to have certain information shared with our third party business partners when you enter a contest or sweepstakes or elect to receive marketing offers or other information. If you do not elect to have your information shared, it will not be shared with such third parties. We take measures to help ensure that our partners protect the confidentiality, integrity, and security of any information we share with them. However, we are not responsible for the privacy practices of our business partners, which may use your information for their own purposes.

Third-Party Ad Serving and Audience and Traffic Measurement Services: We may use third-parties to serve advertisements on the Services. These third parties may set their own cookies or similar web technologies to collect information about users’ online activities over time and across different websites.

Administrative or Legal Process: We may disclose your information to third parties in order to protect the legal rights, safety, and security of Technologies ESA Inc., our corporate affiliates, subsidiaries, business partners, and the users of our Services; enforce our Terms of Use; respond to and resolve claims or complaints; prevent fraud or for risk management purposes; and comply with or respond to law enforcement or legal process or a request for cooperation by a government or other entity, whether or not legally required.

Interactive Features: We may share information with third parties when you post information to a user profile or a public area of the Services, such as a chat room, forum, blog, or other community tool. If you post to these interactive features, it will be publicly available and you may receive unsolicited messages from other parties. We cannot ensure that parties who have access to such information will respect your privacy. Please exercise caution when using these features.

Other Parties With Your Consent: We may share information with third parties when you consent to such sharing. For example, if you win a contest or sweepstakes, we may ask your permission to publicly post certain information on the Services identifying you as the winner.

Aggregate Information: We may share aggregate information, such as demographics and usage statistics, with advertisers, sponsors or other organizations.

Geolocation Information: We may share your geolocation information with service providers that perform certain functions or services on our behalf. These companies are authorized to use precise geolocation information only as necessary to provide these services to us. We also may share your geolocation information with third parties so that they may provide you with geographically relevant advertising. If you wish to stop the further collection of your geolocation information, whether collected through location services, Bluetooth, or microphone access technology, please opt-out using your device settings.

4.User Generated Content

Your permission to use our app is conditioned upon the posting and conduct restrictions.

By transmitting and submitting any User content while using the app, you agree as follows:

You are solely responsible for the User Content that you upload and post.

You are solely responsible for your account and the activity that occurs while signed in to or while using your account

You will not post information that harasses threatens, impersonates, or intimidates any person

You will not post any information that is abusive, obscene, defamatory, libelous, racially, sexually, religiously, or otherwise objectionable and offensive.

You hereby agree that we have the right to determine whether your User content submissions are appropriate and comply with these Terms of use, remove any and/or all your submissions, and terminate your account with or without prior notice.

5.Cookies and Similar Technologies

The Services use technologies such as cookies, beacons, tags and scripts. These technologies are used for a variety of purposes, such as analyzing trends, administering the Services, analyzing how users interact with the Services, and gathering demographic information. By using the Services, you consent to our use of cookies and similar technologies.

Users can control the use of cookies at the individual browser level. If you reject cookies, you may still use our Services, but your ability to use certain features may be limited.

We may use mobile analytics software to allow us to better understand the functionality of our Services. This software may record information such as how often you use an application, the events that occur within the application, aggregated usage, performance data, and where an application was downloaded from.


We partner with third party advertisers to serve and display advertising on the Services. These partners may use cookies and Web beacons to collect information about your activities across different websites and services to provide you with relevant advertising. To serve and display advertising relevant to your location, the Services may also track your device’s precise geolocation by responding to beacons or inaudible signals sent to your device’s microphone. If you do not want the location of your device to be tracked by the Services, please opt-out using your device settings.

7.Social Networking

You may be able to link an account from a social networking service (e.g., Facebook, Google+, Yahoo!) to an account through our Services. This may allow you to use your credentials from the other site or service to sign in to certain features on our Services. If you link your account from a third-party site or service, we may collect information from those third-party accounts, and any information that we collect will be governed by this Privacy Policy.

8.Links to Other Websites

The Services may contain links to other websites or online services that are operated and maintained by third parties and that are not under our control or maintained by us. Such links do not constitute an endorsement by us of those other websites, the content displayed therein, or the persons or entities associated therewith. This Privacy Policy does not apply to this third-party content. We encourage you to review the privacy policies of these third-party websites or services.

9.Data Security and Data Integrity

We have adopted security procedures to help protect against loss, misuse, interference, disclosure, destruction, alteration and unauthorized access to the information you provide to us. We encrypt the transmission of that information using secure socket layer technology (SSL). We also maintain reasonable procedures to help ensure that such data is reliable for its intended use and is accurate, complete and current.

Please note that no data transmission or storage can be guaranteed to be 100% secure. As a result, while we strive to protect your information and privacy, we cannot guarantee or warrant the security of any information you disclose or transmit to the Services and cannot be responsible for the theft, destruction, or inadvertent disclosure of your information.

10.Data Retention

We will retain your information only for as long as reasonably necessary for the purposes set out above, considering criteria such as applicable rules on statute of limitations, legal requirements and the duration of your use of our website and receipt of our Services.

The person has the right to request the deletion of personal data for continuous processing, this right is known as “the right to be forgotten”.

The data can still remain in the system backup files, which will be deleted periodically. Information can be removed from our database with prior request to [email protected]

We promise to carry out the elimination within a period of one month (30 calendar days). Whenever possible, we will try to complete the application before the deadline.

11.Children’s Privacy

The Services do not knowingly collect, use, or disclose personal information from children under the age of 13. If we are made aware we have collected personal information from a child under 13 years old in a manner that is inconsistent with the Children’s Online Privacy Protection Act (“COPPA”), we will delete this information as soon as possible.

12.Communications Preferences and Access

You may choose to receive promotional emails, newsletters, push notifications, and similar communications from us. You may opt out of receiving commercial emails from us by clicking on the opt-out or “unsubscribe” link included in the commercial e-mails you receive. You may opt out of receiving push notifications by turning off push notifications at the device level. Please note that opt-out requests may take some time to be effective.

We will retain your information for as long as your account is active or as needed to provide you services. We will retain and use your information as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements.

13.Changes To This Privacy Policy

We may update this Privacy Policy to reflect changes to our information practices. We encourage you to periodically review this page for the latest information on our privacy practices.

14.International Users

Please note that the Services are directed towards users who reside in Latin America. Our website is hosted in Canadá. By using the Services, you consent to the collection, storage, processing, and transfer of your information in and to Canadá, pursuant to the laws of Canadá. While some of these countries may not offer the same level of privacy protection as your own, we commit to uphold the privacy protections as explained in this Policy and take appropriate steps to ensure that recipients of your information are bound to duties of confidentiality and where applicable we implement measures such as standard data protection contractual clauses to ensure that any transferred information remains protected and secure.

15.Users from the European Union

This section of the Privacy Policy applies only if you use our website or Services covered by this Privacy Policy from a country that is a Member State of the European Union, (the “EU”), and supplements the information in this Privacy Policy.

In compliance with the provisions of current legislation on data protection, and in the context of the new regulatory framework established by virtue of the provisions of Regulation (EU) 2016/679 of the European Parliament and of the Council, of 27 April 2016, relating to the protection of natural persons with regard to the processing of personal data and the free circulation of said data (hereinafter, the “General Regulations”), and the national regulations on the protection of personal data, we inform you that the personal data that you provide us (hereinafter, the “Data”), will be subject to processing by Technologies ESA Inc..

In addition to collecting and processing your Personal Data via your use of the Services, as described in this Privacy Policy (see section entitled “Information Collection”).

Technologies ESA Inc. is the data controller for processing of information defined as personal data under applicable data protection law (“Personal Data”) when you use the Services.

In some instances, you may be required to provide us with Personal Data for processing as described above, in order for us to be able to provide you all of our Services, and for you to use all the features of our website.

Automated Decision-Making: We use automated decision-making technologies, including profiling, to support our data processing activities. Our automated decision-making capabilities include logic that will send triggered messages based on fan data or behaviour. By using this logic, it helps us provide a better fan experience or you, this means that receiving messages based on data you have provided (for example a birthday email) or a behaviour (watching a video).

Your Rights: You may be entitled, in accordance with applicable law, to object to or request the restriction of processing of your Personal Data, and to request access to, rectification, of (e.g. if your Personal Data changes or is out of date), erasure of and portability of your own Personal Data in certain circumstances. Requests should be submitted by contacting us by emailing Contact@esatechnologies.

If you are aware of changes or inaccuracies in your information, you should inform us of such changes so that our records may be updated or corrected. You may lodge a complaint with your local supervisory authority if you consider that our processing of your Personal Data infringes applicable law.Photos created by TrueDepth API are stored until the user decides to delete his account.