Privacy Policy & Data Protection

1. Introduction

This Privacy Policy explains how we collect, use, store, and protect your personal data when you use Trezio.

Trezio is a digital platform that transforms physical spaces—primarily shopping malls, as well as museums and cultural venues—into gamified experiences through interactive scavenger hunts. The platform is owned and operated by FCTU SA, a company incorporated under Swiss law, with its registered office at 123 Route de Meyrin, 1219 Châtelaine, Geneva, Switzerland.

Trezio is available via our website (trezio.io), Android application, and iOS application (collectively, the "Platform").

By using Trezio, you agree to the collection and use of your data as described in this policy. If you do not agree, please do not use our services.

2. Who We Are

FCTU SA is the data controller responsible for your personal data. You can contact us at:

Email: contact@fctu.io Address: 123 Route de Meyrin, 1219 Châtelaine, Geneva, Switzerland

3. What Data We Collect

We collect the following categories of personal data:

3.1 Identification and Contact Data

This includes your name, email address, and date of birth. We use this information to create and manage your account, provide customer support, and communicate with you about our services.

3.2 Technical and Connection Data

This includes your IP address, browser type, device identifiers, operating system, and session information. We collect this data to ensure platform security, maintain session integrity, and improve our services.

3.3 Transaction Data

This includes purchase history, ticket identifiers, and payment records. We use this data for billing, access verification, and to fulfil our contractual obligations to you.

3.4 App Usage and Gameplay Data

This includes your game progression, leaderboard entries, quiz responses, completed scavenger hunts, and in-app interactions. We collect this data to deliver and personalise your gaming experience.

3.5 Location Data

With your permission, we collect GPS data and Bluetooth Low Energy (BLE) signals. Location data is essential for our location-based scavenger hunts and to verify your presence at participating venues.

3.6 Device Permissions

Our mobile applications may request access to your camera (for augmented reality features and QR code scanning), microphone, and motion sensors. These permissions are requested explicitly through your device's native consent system and are only activated after your approval.

3.7 Marketing Preferences

If you subscribe to our newsletter or opt in to marketing communications, we store your email address and communication preferences to send you updates about Trezio.

4. How We Use Your Data

We use your personal data for the following purposes:

To authenticate your identity and secure access to your account
To deliver and personalise our services, including scavenger hunts and augmented reality experiences
To process transactions and manage billing
To provide customer support and respond to your enquiries
To analyse usage patterns and improve platform performance
To send you marketing communications (only if you have opted in)
To comply with legal obligations under GDPR and Swiss data protection law
To power AI-driven features that generate content for scavenger hunts, including clues, images, and riddles

5. AI-Generated Content

Trezio uses artificial intelligence to generate content for our scavenger hunts, including clues, riddles, and images. This AI processing helps us create engaging and varied experiences across different venues. The AI systems may use aggregated and anonymised usage data to improve content quality, but individual personal data is not used to train these systems.

6. Legal Basis for Processing

We process your personal data based on the following legal grounds:

Contract Performance: Processing necessary to provide you with access to Trezio, including account management, gameplay, and billing.
Legal Obligation: Processing required to comply with applicable laws, including tax, audit, and data retention requirements.
Consent: Processing based on your explicit consent, such as for location services, cookies, and marketing communications. You may withdraw consent at any time.
Legitimate Interest: Processing necessary for our legitimate business interests, including service optimisation, fraud prevention, and analytics, where these interests are not overridden by your rights.

7. Data Sharing

We do not sell your personal data. We may share your data with the following categories of recipients:

Service Providers: We work with trusted third-party processors who help us operate the platform. These include AWS (hosting), Stripe (payment processing), Firebase (analytics), Unity Technologies (gameplay analytics), and Google (GA4, Google Tag Manager).
Venue Partners: Shopping malls, museums, and cultural venues that host Trezio experiences may receive aggregated analytics about scavenger hunt participation at their locations. This data is shared under strict contractual agreements.
Public Authorities: We may disclose data to law enforcement or regulatory bodies when required by law.

8. Data Location and Transfers

Your personal data is stored on servers located in France within the European Union. We do not transfer your data outside the EU or Switzerland. All our service providers who process personal data do so within the EU/EEA, ensuring your data remains protected under European data protection standards.

9. Data Security

We implement appropriate technical and organisational measures to protect your personal data, including:

SSL/TLS encryption for data in transit
Role-based access controls and multi-factor authentication for our systems
Regular security audits and vulnerability assessments
Daily backups and incident response procedures
Breach notification processes in compliance with GDPR (within 72 hours of becoming aware of a qualifying breach)

10. Data Retention

We retain your personal data only for as long as necessary to fulfil the purposes described in this policy:

Account data is retained for the duration of your account and deleted upon request
Transaction records are retained for up to 10 years to comply with accounting and tax requirements
Analytics data is retained in anonymised form for service improvement purposes
Marketing preferences are retained until you unsubscribe or request deletion

11. Your Rights

Under GDPR and Swiss data protection law, you have the following rights:

Right of Access: You can request a copy of the personal data we hold about you.
Right to Rectification: You can ask us to correct inaccurate or incomplete data.
Right to Erasure: You can request deletion of your personal data, subject to legal retention requirements.
Right to Restriction: You can ask us to limit how we process your data in certain circumstances.
Right to Data Portability: You can request your data in a structured, commonly used format.
Right to Object: You can object to processing based on legitimate interests or for direct marketing purposes.
Right to Withdraw Consent: Where processing is based on consent, you can withdraw it at any time without affecting the lawfulness of prior processing.

To exercise any of these rights, please contact us at contact@fctu.io. We will respond within 30 days. If you are not satisfied with our response, you have the right to lodge a complaint with a supervisory authority.

12. Children's Privacy

Trezio is intended for users aged 13 and older.

Users aged 16 or older may create and use an account independently.
Users aged 13 to 15 require parental or legal guardian consent. When creating an account, users are asked to provide their date of birth. If the user is under 16, we display a notice requiring parental consent before proceeding.
Users under 13 are not permitted to use Trezio.

If we become aware that we have collected personal data from a child under 13, we will take steps to delete that information promptly.

13. Cookies and Tracking Technologies

We use cookies and similar tracking technologies to:

Maintain your session and keep you logged in
Analyse how you use our platform to improve our services
Personalise your experience
Measure the effectiveness of our communications

We use Google Analytics 4, Firebase Analytics, and Google Tag Manager for analytics purposes. Non-essential cookies are only placed after you provide explicit consent via our cookie banner. You can manage your cookie preferences at any time through the "Cookie Settings" option on our website.

14. Changes to This Policy

We may update this Privacy Policy from time to time to reflect changes in our practices or applicable law. When we make significant changes, we will notify you through the platform or via email. We encourage you to review this policy periodically.

15. Contact Us

If you have any questions, concerns, or requests regarding this Privacy Policy or how we handle your personal data, please contact us:

FCTU SA

123 Route de Meyrin

1219 Châtelaine, Geneva

Switzerland

Email: contact@fctu.io

Website: trezio.io

Privacy Policy – Trezio