This Privacy Policy sets out the basis on which we will process any Personal Data that we may collect

about you as a visitor to our website at www.abyss-project.fr and our customers or potential customers

using our tools and Software as a Service (SaaS) solutions (“Services”), or other business partners or in

any other cases where we specifically state that this policy will apply. This policy further sets out how

we protect your privacy and your rights in respect of our use of your Personal Data. If you are a user of

our Android mobile applications Abyss Cloud and Abyss Memories, please refer to our App Privacy

Policy.

WHO IS THE DATA CONTROLLER?

A “data controller” is a person or organization who alone or jointly determines the purposes for which,

and the manner in which, any personal data is, or is likely to be, processed. In this sense, Abyss Project,

Mehdi "Scylla" Abdelkrim, Saint-Louis, France (“Abyss Project”, “we”, “us”, “our”) is the data

controller. If you have any questions about data protection at Abyss Project in general, you can reach

us by email using contact@abyss-project.fr.

WHAT IS PERSONAL DATA?

Personal data is any information that relates to an identified or identifiable living individual. Different

pieces of information, which collected together can lead to the identification of a particular person, also

constitute Personal Data.

WHAT IS SPECIAL CATEGORY DATA?

Special category data is Personal Data that needs more protection because it is sensitive. This includes

Personal Data revealing racial or ethnic origin, political opinions, religious or philosophical beliefs,

trade union membership, genetic data, biometric data. As well as, data concerning health, a person’s

sex life; and a person’s sexual orientation. In order to lawfully process Special Category Data, it is

necessary to consent to the processing

WHY DO WE HAVE A PRIVACY POLICY?

France's Data Protection Act (Law n° 2018-493 and Ordinance n° 2018-1125) (“DPA”) and the EU's

General Data Protection Regulation (“GDPR”) control how your Personal Data is used by us. We are

also required to explain which Personal Data we collect from you via our website and services, what

we use it for, when we delete it and how your data is protected.

WHAT ARE THE LEGAL BASES FOR PROCESSING PERSONAL DATA

All Personal Data that we obtain from you via our website will only be processed for the purposes

described in more detail below. This is done within the framework of the DPA and the GDPR and only

if at least one of the following applies: a) you have given your consent, b) the data is necessary for the

fulfillment of a contract / pre-contractual measures, c) the data is necessary for the fulfillment of a legal

obligation, or d) the data is necessary to protect the legitimate interests of our company, provided that

your interests are not overridden.

WHAT PERSONAL DATA DO WE COLLECT FROM YOU?

a) Collection of access data and log files

When you visit our website, we collect the Personal Data that your browser automatically transmits to

our server. This is technically necessary for us to display our website and to ensure its stability and

security. In this sense, we collect the following data: a) IP address of the requesting computer, b) Date

and time of access, c) name and URL of the file accessed, d) website from which the access was made

(referrer URL), e) browser used and, if applicable, the operating system of your device as well as the

name of your access provider. The legal basis is our legitimate interest.

b) Hosting

We do not use a hosting service for the purpose of operating our website and instead our website is self-

hosted. In doing so we process inventory data, contact data, content data, contract data, usage data, meta

data and communication data of our customers, interested parties and visitors ourselves and on our own

servers. The legal basis is our legitimate interests in an efficient and secure provision of the website and

services in conjunction with the provision of contractual services.

c) Cookies

For the processing of personal data using cookies and similar technologies on our website, please refer

to our Cookie Policy. The legal basis for the use of cookies is our legitimate interest or your consent

when you agree to the use of technically non-essential cookies as further explained in our Cookie Policy.

d) Cookie consent

As set out in France’s Trust in the Digital Economy Act (L. 34-5 of the Postal and Electronic

Communications Code) (“Act”) and the EU`s Privacy and Electronic Communications Directive

(“PECD”), we need to obtain consent for the use of technically non-essential cookies. For this purpose

we use a cookie consent tool, to obtain your consent to the storage of cookies and to document this

consent. When you enter our website, the following Personal Data is transferred to us via our cookie

consent tool: a) Your consent(s) or revocation of your consent(s); b) Your IP address; c) Information

about your browser; d) Information about your device; e) Time of your visit to our website. The basis

for processing is our legitimate interest and your consent.

e) Economic analyses and market research

For business reasons, we analyze the data we have on business transactions, contracts, enquiries,

browsing behavior etc. The analyses serve us alone and are not disclosed externally and processed using

anonymous analyses with summarized and or anonymized values. For this purpose we use Google

Analytics and you can find more information about Google Analytics in our Cookie Policy. The legal

basis is our legitimate interest and your consent.

f) Google Tag Manager

We use Google Tag Manager, which allows website tags to be managed via an interface. The Google

Tag Manager only implements tags. No cookies are set, and no Personal Data is collected. Google Tag

Manager triggers other tags that may collect data but does not itself access this data. The legal basis for

using Google Tag Manager is our legitimate interest.

g) Contact options

We process and store the Personal Data provided in the contact enquiry solely for the purpose of

processing and responding to your enquiry and contacting you. If you contact us, we will process the

data you provide to respond to you and answer your questions and requests. In doing so, the principle

of data economy and data avoidance is observed in that you only have to provide the data that we

absolutely need from you in order to contact you. These are usually your first and last name, your email

address, the topic selection and the message itself. The legal basis for processing is our legitimate

interest, the provision or initiation of a contractual service and your consent.

h) Registration

As part of the registration process, users provide their email and password. The data provided will be

used for the purposes of creating and using the account and providing and/or using our services.

Alternatively, you are able to sign up using the convenience login and sign up from Discord. For

convenience login and sign up, you will be asked to provide your basic information (i.e., name, email

address, and display picture) linked to your account. When registering via our convenience function,

you agree to the relevant terms and conditions and consent to certain data from your respective profile

being transferred to us.

In the context of the use of our registration and convenience log in and sign up as well as the use of the

user account, the legal basis for the data processing is the fulfillment of our contractual obligations and,

in individual cases, the fulfillment of our legal obligations as well as consent.

i) Using our Tools and SaaS Services

If you wish to use our tools and SaaS services (Abyss Crypt, Abyss Cloud, Abyss Memories,

AbyssBanking), we process the data you provide which may include Personal Data, Special Category

Data and non-personal data (“Service Data”). We recognise that you own your Service Data and provide

you with complete control over your Service Data by providing you the ability to a) access your Service

Data, b) share your Service Data, and c) request export or deletion of your Service Data.

When we process Service Data, we become your Data Processor or in other words, we will process the

Service Data involved in your use of our services in accordance with your instructions and shall use it

only for the purpose of providing you our services.

We ensure that access by our employees to your data is only available on a need-to-know basis,

restricted to specific individuals, and is logged and audited. We communicate our privacy and security

guidelines to our employees and enforce privacy and protection safeguards strictly. The legal basis for

the processing of your Service Data is our obligation to fulfill the contract we have with you.

Please note: Some jurisdictions may require you to disclose your use of our Services and us as your

processor in your privacy policy and/or data processing agreement as applicable. For this purpose all

Service Data processed by us will be processed using our own server and take appropriate legal

precautions and corresponding technical and organizational measures to ensure the protection of your

Service Data.

j) Your end users and our Tools and SaaS Services

If you are a Developer and you design, integrate and configure our Tools and SaaS Services into your

developments, we may also process Personal Data, Special Category Data and non-personal data of

your end users (“End User Data”). The End User Data processed by us depends on how you are using

our Tools and SaaS Services and the requests you and/ your end users are submitting. In this sense you

have full control over how you and your end user are using our Services, for example by using

configuration options and settings, and the End User Data that is processed by us.

Further and if you are providing us with End User Data relating to a third party, you agree a) that you

have in place all necessary appropriate consents and b) that such third party has read this Privacy Policy.

You agree to indemnify us in relation to all and any liabilities, penalties, fines, awards, or costs arising

from your non-compliance with these requirements.

The legal basis is the provision of a contractual service. Further and in accordance with the DPA and

the GDPR we act as the Data Processor. Some jurisdictions may require you to disclose your use of our

Services and us as your processor in your privacy policy and/or data processing agreement as applicable.

k) Support ticket

If you create a support ticket, we will request Service Data and, where applicable, End User Data in

accordance with your request, this may include your name, email address and other order related data

you voluntarily provide. The data provided is not shared with third parties and cannot read your data

when it is entered. If you submit a support ticket, we process the data for the purpose of processing and

handling your ticket.

Our employees will also have access to data that you knowingly share with us for technical support or

to import data into our services. We communicate our privacy and security guidelines to our employees

and enforce privacy safeguards strictly. The legal basis of the data processing is our obligation to fulfill

the contract and/or our legitimate interest in processing your support ticket.

l) Payment Data

If you make a purchase for service credits, your payment data will be processed via our payment service

provider Stripe. Payment data will solely be processed through Stripe and we have no access to any

Payment Data you may submit. The legal basis for the provision of a payment system is the

establishment and implementation of the contract.

m) Our Community

We process the Personal Data that arises when you use our community services. In particular, this

requires you to join our server and community on Discord. If you contact or connect with us via Discord,

we and Discord are jointly responsible for the processing of your data and enter into a so-called joint

controller agreement. The legal basis is our legitimate interest, your consent or, in some cases, the

initiation of a contract, if any.

n) Administration, financial accounting, office organization, contact management

We process data in the context of administrative tasks as well as organization of our business, and

compliance with legal obligations, such as archiving. In this regard, we process the same data that we

process in the course of providing our contractual services. The processing bases are our legal

obligations and our legitimate interest.

o) Promotional use of your data

We use your data (email) within the legally permissible scope for marketing purposes, e.g., to draw

your attention to special promotions and discount offers via email. In addition, we reserve the right to

use your first and last name as well as your postal address for our own advertising purposes, e.g., to

send you interesting offers and information about our products by post. This serves to protect our

legitimate interests.

DISCLOSURES OF YOUR PERSONAL DATA

We will not disclose or otherwise distribute your Personal Data to third parties unless this is a) necessary

for the performance of our services b) you have consented to the disclosure, c) or if we are legally

obliged to do so e.g., by court order or if this is necessary to support criminal or legal investigations or

other legal investigations or other legal proceedings; or proceedings at home or abroad or to fulfill our

legitimate interests.

INTERNATIONAL TRANSFER

We may transfer your Personal Data to other companies as necessary for the purposes described in this

we have contractual arrangements regarding such transfers. We take all reasonable technical and

organizational measures to protect the Personal Data we transfer.

SOCIAL MEDIA

We are present on social media on the basis of our legitimate interest (currently, X (formerly Twitter)

and Instagram). If you contact or connect with us via social media, we and the relevant social media

platform are jointly responsible for the processing of your data and enter into a so-called joint controller

agreement. The Personal Information collected when contacting us is to handle your request and the

bases are both your consent and our legitimate interest.

In addition, your data may be processed for market research and advertising purposes. For example,

usage profiles can be created from your usage behavior and the resulting interests. This allows, for

example, advertisements to be placed within and outside the platforms that presumably correspond to

your interests. The legal basis is our legitimate interest.

When you visit our social media profiles, we, as the operator of the profile, process your actions and

interactions with our profile (e.g., the content of your messages, enquiries, posts or comments that you

send to us or leave on our profile or when you like or share our posts) as well as your publicly viewable

profile data (e.g., your name and profile picture). Which Personal Information from your profile is

publicly viewable depends on your profile settings, which you can adjust yourself in the settings of your

social media account. The legal basis is our legitimate interest and your consent.

HOW LONG DO WE KEEP YOUR PERSONAL DATA?

We will delete your Personal Data when we no longer need such Personal Data, for instance where:

● it is no longer necessary for us to retain your Personal Data to fulfill the purposes for which we

had collected it;

● we believe that your Personal Data that we hold is inaccurate; or

● in certain cases where you have informed us that you no longer consent to our processing of

your Personal Data.

Sometimes, however there are legal or regulatory requirements which may require us to retain your

Personal Data for a specified period, and in such cases we will retain your Personal Data for such

specified period; and we may need to retain your Personal Data for certain longer periods in relation to

legal disputes, and in such cases we will retain it for such longer periods to the extent required.

HOW WE SECURE YOUR PERSONAL DATA

We take appropriate organizational, technical, and physical measures to help safeguard against

accidental or unlawful destruction, loss, alteration, and unauthorized disclosure of, or access to, the

Personal Data we collect and process. However, no method of collection, storage, or transmission is

100% secure. You are solely responsible for protecting your password, limiting access to your devices,

and signing out of websites after your sessions.

LINKED SITES

For your convenience, there may be hyperlinks on our website that link to other websites. We are not

responsible for, and this Privacy Policy does not apply to the privacy practices of any linked websites

or of any companies that we do not own or control. The website links may collect information in

addition to the information we collect.

We do not endorse any of these linked websites, their products, services, or any of the content on their

websites. We encourage you to seek and read the Privacy Policy of each linked website that you visit

to understand how the information that is collected about you is used and protected.

YOUR RIGHTS AND PRIVILEGES

a) Privacy rights

You can exercise the following rights:

● The right to access;

● The right to rectification;

● The right to erasure;

● The right to restrict processing;

● The right to object to processing;

● The right to data portability;

b) Updating your information and withdrawing your consent

If you believe that the information we hold about you is inaccurate or request its rectification, deletion,

or object to legitimate interest processing, please do so by contacting us.

c) Access Request

In the event you want to make a Data Subject Access Request, please contact us. We will respond to

requests regarding access and correction as soon as reasonably possible. Should we not be able to

respond to your request within thirty (30) days, we will tell you why and when we will be able to

respond to your request. If we are unable to provide you with any Personal Data or to make a correction

requested by you, we will tell you why.

d) Complaint to a supervisory authority

The Commission nationale de l'informatique et des libertés (CNIL) (www.cnil.fr) is the relevant

authority in France. If you believe that the processing of your Personal Data is not lawful, you can lodge

a complaint with a data protection supervisory authority. We would, however, appreciate the chance to

deal with your concerns before you approach the CNIL or any other supervisory authority.

e) What we do not do

● We do not request Personal Data from minors and children;

● We do not process special category data without obtaining prior specific consent;

● We do not use Automated decision-making including profiling; and

● We do not sell your Personal Data.

HELP AND COMPLAINTS

If you have any questions about this policy or the information we hold about you please contact us by

email using contact@abyss-project.fr

CHANGES

The first version of this policy was issued on Saturday, 10th of August, 2024 and is the current version.

Any prior versions are invalid and if we make changes to this policy, we will revise the effective date.