Who We Are
ColdTrace is developed and operated by SACLIC STUDIO, a Société par Actions Simplifiée (SAS) incorporated in France.
| Legal name | SACLIC STUDIO |
| Legal form | SAS — Société par Actions Simplifiée |
| SIREN | 935 200 071 |
| VAT | FR64 935 200 071 |
| Registered address | 60 Rue François Ier, 75008 Paris, France |
| Contact | contact@saclicstudio.com |
As a French company, SACLIC STUDIO is subject to the General Data Protection Regulation (GDPR — Regulation EU 2016/679) and the French Data Protection Act (Loi Informatique et Libertés).
Scope
ColdTrace is an immersive mobile experience — a fictional, interactive narrative designed for entertainment. This Privacy Policy explains how we handle (and mostly don't handle) your personal data when you use the app.
Data We Collect
Subscription Data
If you purchase a subscription or in-app purchase, basic transaction data (subscription status, anonymous user ID) is processed by Adapty on our behalf to unlock premium features. We do not store your payment card details — those are handled exclusively by the App Store or Google Play.
Legal Bases
| Data | Purpose | Legal Basis |
|---|---|---|
| Anonymous user identifier | Link session across app launches | Contract performance |
| Subscription status & purchase history | Unlock premium content | Contract performance |
| Anonymized usage metrics (if any) | App stability and improvement | Legitimate interest (GDPR Art. 6(1)(f)) |
Adapty — Subscription Infrastructure
In-app purchases and subscription management in ColdTrace are powered by Adapty.
Adapty may process data outside the EU/EEA. Where such transfers occur, appropriate safeguards including Standard Contractual Clauses (SCCs) are in place.
Further information: adapty.io/privacy-policy
Data Sharing
We do not sell your data. Period. We share information only in the following limited circumstances.
Service Providers
| Provider | Role | Data Shared | Location |
|---|---|---|---|
| Adapty | Subscription management | Subscription status, anonymous user ID | EU / USA (SCCs apply) |
Legal Obligations
We may disclose data if required by law, court order, or to protect the rights, property, or safety of SACLIC STUDIO, our users, or the public.
Business Transfers
If SACLIC STUDIO is involved in a merger, acquisition, or asset sale, we will provide advance notice before your data is transferred and becomes subject to a different privacy policy.
International Data Transfers
SACLIC STUDIO is based in France. Our sole service provider, Adapty, may process data outside the EU/EEA. Where such transfers occur, they are governed by:
You may request a copy of the relevant transfer mechanisms at contact@saclicstudio.com.
Data Retention
Given our minimal data collection, retention periods are equally minimal.
- Anonymous user identifier Until account deletion + 30 days
- Subscription history 5 years (legal accounting obligation)
- Anonymized usage logs (if collected) 13 months rolling
You can request deletion of all data associated with your account at any time by contacting us.
Your Rights Under the GDPR
As a resident of the EU/EEA, you have the following rights regarding your personal data.
If you believe we have not handled your data correctly, you may lodge a complaint with the Commission Nationale de l'Informatique et des Libertés (CNIL):
Data Security
We implement appropriate technical and organizational measures to protect any data processed in connection with ColdTrace.
Children's Privacy
ColdTrace is not intended for users under the age of 16. We do not knowingly collect personal data from anyone under 16.
If you believe a child has provided us with personal data, please contact us immediately at contact@saclicstudio.com and we will delete it promptly.
Changes to This Policy
We may update this Privacy Policy from time to time, particularly if there are legal, technical, or product changes. When we make material changes, we will:
Continued use of the Service after changes take effect constitutes acceptance of the updated policy.
Contact
SIREN 935 200 071