SACLIC STUDIO — PRIVACY DOCUMENT

Spylisa

Privacy Policy — Fictional Experience

Last Updated July 23, 2026
Jurisdiction France — GDPR
External Services Mixpanel · Google AdMob
FILE 01

Who We Are

Spylisa is developed and operated by SACLIC STUDIO, a Société par Actions Simplifiée (SAS) incorporated in France.

Legal nameSACLIC STUDIO
Legal formSAS — Société par Actions Simplifiée
SIREN935 200 071
VATFR64 935 200 071
Registered address60 Rue François Ier, 75008 Paris, France
Contactcontact@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).

FILE 02

Scope

Spylisa is a mobile application designed as an immersive, fictional experience that simulates a smartphone interface. Its purpose is purely entertainment: users explore interactive storytelling elements inside a simulated digital environment.

Important — Fiction only Spylisa is not a real monitoring, tracking, or surveillance tool. It cannot access another person's device, messages, or location. All content within the app is entirely fictional and created solely for entertainment.
Acknowledgement By using Spylisa, you confirm that you have read and understood this Privacy Policy.
FILE 03

Data We Collect

Spylisa never asks you for your personal identity.
You are not required to provide your name, email, phone number, or any identifying detail to use the app. In the free, ad-supported version (Android), our advertising partners process a mobile advertising identifier and basic device data to display ads — see Advertising.

What Spylisa does NOT access

Spylisa does not request, store, or access personal content stored on your device. Specifically, it does not access:

Contacts
Photos or media files
Device microphone
Device camera
Precise or approximate location
Messages or private conversations
Personal identity information

The experience offered by Spylisa is fully contained within the application itself and does not rely on real user data to function.

—◆—

Legal Bases

DataPurposeLegal Basis
Anonymized usage metrics (via Mixpanel)App stability and improvementLegitimate interest (GDPR Art. 6(1)(f))
Advertising identifier & device data (ad-supported version)Display and measure third-party adsConsent (GDPR Art. 6(1)(a)) where required
No Sensitive Data Spylisa does not process any special category data (health, biometric, precise location, or financial data), and does not link analytics to any identified person.
FILE 04

Analytics — Mixpanel

To help improve the stability and usability of Spylisa, the app may use analytics tools. These allow us to understand general usage patterns such as:

Number of sessions
Screens viewed
Feature interactions
App performance metrics
Anonymized These analytics tools receive only limited, anonymized information about general application usage. No personal data is collected or linked to any specific person.

The analytics provider we use is Mixpanel. Mixpanel processes this data on our behalf under a Data Processing Agreement and may only use it on our documented instructions.

Further information: mixpanel.com/legal/privacy-policy

FILE 05

Advertising

The free, ad-supported version of Spylisa (on Google Play / Android) displays third-party advertisements to keep the app free.

Ads are delivered through Google AdMob and its mediation partners. To display and measure ads, these partners may collect and process:

Advertising identifier (Google Advertising ID / AAID)
Device & app information (model, OS, app version)
IP address & approximate (coarse) location
Ad interaction & performance data

Personalised Ads & Consent

In the EEA, the UK, and other regions where it is required, we display a consent request (Google User Messaging Platform) before any personalised advertising. You may accept or refuse. If you refuse, you will still see ads, but non-personalised ones.

Your Choices

You can reset or delete your advertising identifier, or opt out of personalised ads, at any time in your device settings (Settings → Google → Ads on Android). You can also update your consent choice from within the app.

PartnerRolePrivacy Policy
Google AdMobAd serving & mediationpolicies.google.com/privacy
Mediation partnersProgrammatic advertising demandManaged through Google AdMob's ad partners
Ads-only, no profiling of your identity These partners process a device-level advertising identifier, not your name or account. You can opt out of personalised ads at any time as described above.
FILE 06

Data Sharing

We do not sell your data. Period. Because Spylisa does not collect personal identity data, sharing is limited to the anonymized data processed by the service providers below.

Service Providers

ProviderRoleData SharedLocation
Mixpanel Product analytics Anonymized usage metrics USA (SCCs apply)
Google AdMob & mediation partners Advertising (free version) Advertising ID, device data, IP, ad interactions USA / global (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.

FILE 07

International Data Transfers

SACLIC STUDIO is based in France. Our service providers, Mixpanel and Google, may process data outside the EU/EEA. Where such transfers occur, they are governed by:

Standard Contractual Clauses (SCCs)
GDPR Chapter V safeguards

You may request a copy of the relevant transfer mechanisms at contact@saclicstudio.com.

FILE 08

Data Retention

Given our minimal data collection, retention periods are equally minimal.

  • Anonymized usage logs (Mixpanel) 13 months rolling
  • Advertising identifier Controlled by you / your device

You can request deletion of any data associated with your device at any time by contacting us.

FILE 09

Your Rights Under the GDPR

As a resident of the EU/EEA, you have the following rights regarding your personal data.

ART. 15
Access
Obtain a copy of the personal data we hold about you.
ART. 16
Rectification
Correct inaccurate or incomplete data we hold.
ART. 17
Erasure
Request deletion of your data — right to be forgotten.
ART. 20
Portability
Receive your data in a structured, machine-readable format.
ART. 18
Restriction
Limit how we process your data in certain circumstances.
ART. 21
Objection
Object to processing based on legitimate interest.
How to exercise your rights Contact us at contact@saclicstudio.com. We respond within 30 days. We may verify your identity before fulfilling a request.

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):

+33 1 53 73 22 22
FILE 10

Data Security

We implement appropriate technical and organizational measures to protect any data processed in connection with Spylisa.

Encryption in transit (TLS)
Encryption at rest
Strict access controls
Regular security reviews
Breach Notification In the event of a breach likely to result in a risk to your rights and freedoms, we will notify the CNIL within 72 hours of becoming aware, as required by GDPR Art. 33.
FILE 11

Children's Privacy

Spylisa 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.

FILE 12

Changes to This Policy

This Privacy Policy may be updated periodically to reflect legal, regulatory, technical, or product changes related to Spylisa. When we make material changes, we will:

Update the "Last Updated" date
Post the new policy on this page
Send an in-app notification where appropriate

Continued use of the app after changes take effect constitutes acceptance of the updated policy.

Contact

CO.
SACLIC STUDIO 60 Rue François Ier, 75008 Paris, France
SIREN 935 200 071
DPA
GDPR complaints: www.cnil.fr · +33 1 53 73 22 22