Privacy policy
What data Maketools processes, why, for how long, with whom, and how to exercise your rights. Cookies included.
Version 0.8 of 30 September 2026 (draft, under legal review).
This English version is a translation; the French version prevails.
This policy explains how MAKETOOLS SAS ("Maketools", "we") processes the personal data of visitors to the site, users of the platform and players, pursuant to Regulation (EU) 2016/679 (GDPR) and French Law No. 78-17 of 6 January 1978 (loi Informatique et Libertés, the French Data Protection Act).
1. Who is responsible
Maketools plays two roles, depending on the data:
- Controller for user accounts, authentication, platform security, billing, support, the anonymous demos of catalogue games, the handling of game reports (moderation), custom game requests (business prospecting), the origin of sign-ups and its internal usage and revenue statistics of the service. This policy describes this processing.
- Processor for the data that customer organisations entrust to us: their members, their invitations, the game sessions played on their games (public games included, with the optional nickname of their players without an account) and their reports. The organisation is then the controller; Maketools follows its instructions in accordance with the data processing agreement. For this data, first contact the organisation concerned; if you write to us, we forward your request to it.
Contact: MAKETOOLS SAS, 149 avenue du Maine, 75014 Paris, France, charlotte@maketools.ai. [To be completed: data protection officer, if one is appointed.]
2. Data processed, purposes and legal bases
| Purpose | Data | Legal basis |
|---|---|---|
| Create and manage your account | Name, work email address, password (stored as a hash, never in plain text), language, date of acceptance of the Terms of Use, linked Google or Microsoft accounts | Performance of the contract (Terms of Use) |
| Authenticate you and protect your account | Sessions (creation and last activity dates), one-time codes, two-step verification secret (encrypted), recovery codes (hashes), date until which you put off the reminder to turn on two-step verification, or date you chose not to see it again, attributes sent by your organisation's SSO | Performance of the contract; legitimate interest (security) |
| Send you the service emails | Email address, name, language, message content (codes, invitations, notifications, including the notice that an organisation requires two-step verification) | Performance of the contract |
| Run the catalogue demos | Game session events (answers, score, duration) without any personal identifier or IP address | Legitimate interest (offering a demo and measuring its use anonymously) |
| Rank the games of the public catalogue | Per game over 28 days: number of active organisations and of completed sessions, aggregated, with no player identifier or organisation name; no figure is published | Legitimate interest (showing the most used games first) |
| Secure the platform and trace sensitive actions | Audit log: action, author (technical identifier), date, IP address, browser, outcome | Legitimate interest (security, evidence); legal obligations |
| Limit abuse | Attempt counters, indexed by hash (never an IP or email in plain text) | Legitimate interest (security) |
| Bill the paid plans and calculate VAT | At Maketools: Stripe customer and subscription identifiers, status, period, number of seats, members' last activity date, payment history (amount, status, date), cancellation reason chosen in Stripe's cancellation survey (closed list, never the free-text comment). At Stripe: company name, billing address, intra-EU VAT number, name, email and phone number of the billing contact, payment method, invoices | Performance of the contract; legal obligations (accounting, tax) |
| Handle game reports (moderation) | Reason, optional message, optional contact email of the person reporting, game concerned, date of the report, decision taken | Legal obligation (French Law No. 2004-575 on confidence in the digital economy (LCEN), Regulation (EU) 2022/2065 on digital services); legitimate interest (protecting the platform's users) |
| Respond to your requests | Email exchanges | Legitimate interest (support) |
| Answer a custom game request and draw up a quote | Name, business email address, company, role, goal of the game, size of the intended audience, deadline, desired language of the game, message; context of the request (originating page, game, organisation or studio game it comes from, site language); origin of the visit (channel, ref and utm_* parameters) |
Pre-contractual measures taken at your request (Article 6(1)(b) GDPR) |
| Measure the use and revenue of the service (internal statistics) | Daily counts: sign-ups, organisations, members, game sessions and minutes played, games created, released and deployed, features used, subscriptions, revenue, access and plan limit refusals. The finest level is the organisation: none of these statistics designates a person | Legitimate interest (steering, improving and promoting the service) |
| Count active users | Pseudonymised activity days: a hash of the account identifier computed with a secret key dedicated to this processing, date, highest role in your organisations. Never a name, email or IP address | Legitimate interest (measuring the actual use of the service) |
| Know how users discover Maketools | Origin of your sign-up: channel (direct access, search engine, social network, other website, campaign, public game, invitation) inferred from the site you came from, without keeping its address or name; ref and utm_* parameters present in the address of the page you arrived on. Optional answer to "How did you hear about Maketools?" when creating an organisation |
Legitimate interest (measuring the effectiveness of our communication) |
Organisations' public games: welcome screen and nickname
Each catalogue demo and each public game of an organisation opens with a Maketools welcome screen (logo, presentation of the platform, QR code to the maketools.ai website). This screen collects no data and sets no tracker; the QR code is a mere image of a link. If you scan it, you open the maketools.ai website like any other visitor.
On a public game, you may choose an optional nickname. This processing is carried out on behalf of the organisation that publishes the game (the controller; Maketools is its processor):
- purpose: showing you on the game's leaderboard and on the presenter mode screen;
- legal basis: set by the organisation; the nickname is optional and you can play without entering one;
- recipients: the whole audience of the game (anyone who views the leaderboard or sees the projected screen), the organisation and Maketools;
- retention: kept with the game session, 13 months, then deleted with it.
As the nickname is public, do not use your full name or any personal information in it.
Reports
Anyone can report a game ("Report this game" button). Maketools processes these reports as controller, to carry out its moderation as a hosting provider. The message and the contact email are optional; the email is only used to reply to you and to inform you of the outcome. The organisation that publishes the game is informed of the ground and the facts underlying a decision concerning it, never of your identity or your email.
Custom game requests
The "Custom game" form (catalogue, studio, game page) lets you ask Maketools to design a game or adapt an existing one. Maketools processes this request as controller, to get back to you, scope your project and send you a commercial proposal.
- Nothing is stored by the platform: your request is forwarded by email to the Maketools sales team, who can reply to you directly; you receive an acknowledgement at the address you entered, which does not repeat your message.
- Recipients: the Maketools sales team; Resend, our email sending processor (section 4).
- Retention: the email is kept in the sales team's mailbox for 3 years after our last contact with you (CNIL recommendation for business-to-business prospecting), then deleted. If the request leads to a contract, the exchanges follow the contract's retention period.
- Answers marked as optional may be left empty. The context (page, game, organisation) is added by the originating page to situate your request; no decision is based on it.
Internal statistics and origin of sign-ups
To steer the service, Maketools keeps aggregated internal statistics: per day, counts (sign-ups, game sessions, published games, subscriptions, revenue…), in total and per organisation. They are stored in a separate database that contains no named data: no name, email, account identifier or IP address. They are computed from the platform's data, including the game sessions played on customer organisations' games, which authorise it in the data processing agreement. When an organisation is deleted, its identifier is replaced there by a random identifier: it is no longer designated.
The only exception, to count active users over 1, 7 and 30 days: the days on which you use the platform are recorded in pseudonymised form (a hash of your account identifier, computed with a secret key reserved for this processing), with your highest role. These days are deleted after 35 days, and as soon as your account is deleted.
The origin of your sign-up is determined without any tracker (section 7): the channel is
inferred from the site you came from, whose address and name are not kept, and the ref and
utm_* parameters are read from the address of the page you arrived on. It is recorded with
your account, included in the export of your data and deleted with your account. The optional
answer to "How did you hear about Maketools?" is recorded with the organisation and deleted with
it.
These statistics are only accessible to the members of the Maketools team authorised to consult them (section 4); they are neither published, nor sold, nor disclosed to any third party. No audience measurement tool and no additional processor is involved. You can object to this processing (section 8).
We do not sell any data, do not carry out targeted advertising and do not take any automated decision producing legal effects concerning you. Game scores measure success in the game; any use your organisation makes of them is its responsibility.
3. Retention periods
| Data | Period |
|---|---|
| User account | Until its deletion; deletion applies to all services within 30 days at most |
| Sessions | 30 days at most, less depending on the organisation's policy and the role |
| One-time codes and tokens | Deleted 7 days after their expiry |
| Invitations | Deleted 7 days after expiry, 30 days after acceptance or revocation |
| Game events and game sessions | 13 months, after which only anonymous aggregates are kept |
| Nickname of a player without an account | Kept with the game session (13 months), deleted with it |
| Reports (reason, message, contact email, game concerned) | 12 months after their creation, then deleted |
| Report exports (CSV, PDF) | Generated on demand, not kept on our servers |
| Unconfirmed imported images | 24 hours |
| Audit log | 12 months, then deleted |
| Billing data at Maketools (including the payment history and the cancellation reason) | Until the organisation is deleted |
| Aggregated internal statistics | No time limit: they contain no personal data; the identifier of a deleted organisation is replaced there by a random identifier |
| Pseudonymised activity days | 35 days, and deleted as soon as the account is deleted |
| Origin of the sign-up | Kept with the account, deleted with it |
| Answer to "How did you hear about Maketools?" | Kept with the organisation, deleted with it |
| Billing information at Stripe (company name, address, VAT number, contact) | For the duration of the subscription, then with the invoices that bear it |
| Invoices (at Stripe) | 10 years (Article L. 123-22 of the French Commercial Code (Code de commerce)); Maketools reads them from Stripe to display them, without storing them (one-minute in-memory cache) |
| Support exchanges | 3 years after the last exchange |
| Custom game requests | Not stored by the platform; the email received by the sales team is kept for 3 years after the last contact, then deleted |
| Technical application logs (errors and service monitoring, without request content) | 30 days, then deleted |
| Backups | Erased at the end of their rotation cycle, 30 days at most |
4. Recipients
Your data is accessible:
- to authorised members of the Maketools team, within the limits of their duties;
- for the internal statistics and the origin of sign-ups, only to the members of the Maketools team authorised to consult them, with a personal key limited to these statistics, which neither shows named data nor allows any change;
- to your organisation, according to the roles it assigns: reports are pseudonymised by
default (
Player-XXXX), unless the organisation chooses the named mode, of which the game informs you; a report filtered on a group of fewer than 5 players is never detailed; - for a custom game request, to the Maketools sales team;
- to the whole audience of a public game, for the nickname you choose there (leaderboard, presenter mode screen);
- for a report, to the Maketools moderation team only; the organisation concerned receives the ground and the facts underlying the decision, without the identity or email of the person who reported;
- to our processors, solely for the needs of the service:
| Processor | Purpose | Location |
|---|---|---|
| Amazon Web Services EMEA SARL | Hosting of the application, databases, files and site, on infrastructure operated directly by Maketools | European Union (Paris, eu-west-3) |
| Resend | Sending transactional emails | United States |
| Stripe | Payment, billing and VAT calculation (Stripe Tax) | Ireland and United States |
The following are also recipients, as separate controllers and only if you or your organisation use them: Google or Microsoft (sign-in with their account), your organisation's identity provider (SSO), and the LMS or LRS (SCORM, xAPI) configured by your organisation. Finally, we may disclose data to authorities that request it within the framework of the law.
5. Transfers outside the European Union
The platform's data is hosted in the European Union. Resend and Stripe may process certain data in the United States. These transfers are governed:
- by the European Commission's adequacy decision on the EU–US Data Privacy Framework, under which Resend and Stripe are certified;
- and, in addition, by the European Commission's standard contractual clauses (2021), incorporated into their data processing agreements.
You can obtain a copy of these safeguards by writing to us.
6. Security
Encryption in transit and at rest, hashed passwords, two-step verification, role-based access control, isolation of organisations, chained audit log, continuous security review: the measures are described in the trust center.
7. Cookies and local storage
The platform uses no advertising or audience measurement cookies, and no third-party trackers. It only sets cookies that are strictly necessary for the service you request, and stores your preferences in your browser. These trackers are exempt from consent (Article 82 of the loi Informatique et Libertés): no banner is therefore displayed.
| Name | Type | Purpose | Duration |
|---|---|---|---|
__Host-dg_session |
Cookie | Keeps your session open | 30 days at most |
__Host-dg_oauth |
Cookie | Binds a Google or Microsoft sign-in to your browser | 10 minutes |
__Host-dg_sso |
Cookie | Binds an SSO sign-in to your browser | 10 minutes |
__Host-dg_handoff |
Cookie | Completes a Google, Microsoft or SSO sign-in | 2 minutes |
__Host-dg_verify |
Cookie | Binds the verification of your email to the browser used to sign up | 30 minutes |
dg-locale |
Local storage | Chosen language | Until cleared |
dg-theme |
Local storage | Chosen light or dark theme | Until cleared |
dg-org |
Local storage | Last organisation viewed | Until cleared |
dg-invitation |
Session storage | Invitation being accepted, kept while you sign in with Google, Microsoft or SSO | Until the invitation is used or the tab is closed |
The public games' welcome screen and its QR code, the nickname, presenter mode, the report form, the custom game request form and the list of invoices set no cookie and use no browser storage.
The origin of your sign-up (section 2) uses no tracker either: it is read from the address of the page on which you arrive on the site and from the indication of the previous site that your browser sends with this page, kept in memory for the duration of your visit, without any cookie or browser storage, then sent with your sign-up request. It is lost if you reload the page or close the tab before signing up.
You can delete this data from your browser settings; deleting the cookies signs you out.
8. Your rights
You have the rights of access, rectification, erasure, restriction, portability and objection (for processing based on legitimate interest), as well as the right to set directives regarding what happens to your data after your death.
- Self-service: Account → Your data lets you export your data (JSON) and delete your account; your profile lets you correct your name and email.
- By email: charlotte@maketools.ai. We may ask you to prove your identity. We respond within one month, which may be extended by two months for a complex request.
For the nickname chosen on an organisation's public game, first contact that organisation (section 1). For a report or a custom game request, write to us at the address above. To object to the counting of your activity days or to the recording of the origin of your sign-up, write to us as well.
You can lodge a complaint with the CNIL, the French data protection authority (www.cnil.fr, 3 place de Fontenoy, TSA 80715, 75334 Paris Cedex 07).
9. Minors
The platform is intended for professional or training use and is restricted to persons aged at least 16.
10. Changes
We may change this policy. Any significant change is notified to you by email or in the platform before it takes effect. The versions and their dates are listed in the version history.