GAMELOFT B2B PRIVACY POLICY

Your privacy is important to us, and we take our responsibility of caring for it seriously. We respect
your privacy rights and are committed to protecting the personal information that is collected about
you. This privacy notice is published on this web page for information purposes only and only
applies to Gameloft B2B business partners. This does not apply to any purchase of consumer
products.
This Privacy Policy describes what information Gameloft collects and how we use, disclose,
transfer, and store it.

Gameloft SE, 14 rue Auber, 75009 Paris, France, including its subsidiary companies (“Gameloft”),
collects, stores, and uses information as a data controller in connection with the physical persons
that are in relation with the legal entity with whom Gameloft has a collaboration, partnership, or
wants to enter in a collaboration, in accordance with this privacy policy (“Privacy Policy”).
Categories of data subjects includes partners, members, directors, officers, employees, managers,
board members, management members, representatives, successors and assignees, third party
agents, counsels and advisors (“Representatives”).

The current policy represents the data protection notice for Representatives and is effective as of
September 1st, 2020.

As your company representative, if you have any questions, comments or concerns regarding our
Privacy Policy and/or practices, please see the “Your rights” section below.

1 – How we collect your information

Gameloft is in business relationships with or plan to begin relationships with your Company.
Gameloft needs to collect and process some professional personal information from you (other
representative in your company or other public sources (for instance your company website).

2 – Purposes for which we may process your information

 compliance with anti-corruption laws, trade compliance laws1 and other applicable laws in
the jurisdictions in which it operates.
 In this regard, Gameloft has implemented risk-based compliance processes reasonably
designed to comply with applicable Trade Control requirements.
 resolution of disputes, investigations or any other petitions / complaints to which Gameloft
is a party;
 offer, negotiate, terminate, modify or terminate, execute the Agreement, activate and
provide services;
 analyzing and responding to complaints;
 detecting and preventing frauds;

1
“Trade Controls” including compliance with the Trade Controls administered and enforced by the U.S. Department of the Treasury’s Office of
Foreign Assets Control (OFAC) and other applicable laws (included but not limited U.S. and EU export control authorities).
  video recording of the presence of data subjects in the physical locations of Gameloft in
order to maintain a high level of security;
 accordingly to specific purposes stated in the documentation relating to the different types
of contract products by the company (eg: specific terms and conditions / product);
 archiving documents (on paper or electronically) between Gameloft and Company, in some
limited cases, for performing internal or external audit activities on Gameloft;
 The possibility to use a Gameloft tools (or applications) in some limited cases as defined
in the agreement between Gameloft and your company;
 the conduct of direct marketing activities involving the communication of promotional
materials and offers through electronic means of communication (telephone, e-mail, SMS
etc.) or by post, in respect of services and products of Gameloft.

3 – Legal basis for processing personal data

Gameloft process the data for the above purposes based on the following legal grounds:
 legitimate interest of Gameloft;
 for concluding and performance of a contract (including prior entering an agreement);
 consent of the data subjects when such consent is necessary;
 legal and/or compliance requirements

4 – Information we collect

Gameloft collects only adequate and relevant information limited to the purposes defined
hereunder.

a – Information provided directly by you or your Company

 identification data included in identity documents, in documents that empower any natural
person to represent the Company in relation to Gameloft as well as those included in the
documents attesting the quality / function occupied within the Company’s organization
(e.g. name, surname, signature);
 the position occupied within the Company's organization;
 limited personal information Gameloft can have access (or receive) from authorities and
according to money laundering and terrorist financing applicable regulations;
 professional contact details: e-mail address, fixed / mobile phone, fax;
 video recording if you visit one our studios or business offices.

b – Information we may collect automatically directly from you when you log in Gameloft
platforms, applications and websites
 IP address and device identifiers (such as your device ID, advertising ID, MAC address,
IMEI);
 Information about your device (such as device name and operating system, browser
information, including browser type and the language you prefer);
 General location and information depending your device settings;
  Name and professional email address;
 Account credentials;
 Cookies (depending the website/ application used). Please refer to Gameloft cookies
policy.

c – Information we may obtain from external public sources under the law
 by consulting external sources (such as institutions, public registers, electronic databases,
etc.) acting under the law (in order to be able to meet specific client knowledge
requirements).
5 – How we retain your information

Gameloft retains, uses and stores your information throughout the contractual relationship and
after its termination, for legal archiving, in compliance with the applicable laws. We want to inform
you that a longer retention period could be required to resolve disputes, or answer regulatory. In
such cases, the collected information will be used and stored until the request is closed.

6 – With whom we may share your personal information

With Gameloft providers & third parties
These providers may be part of the processing described above
Gameloft might organize internal or external event with third parties. These third parties may have
access to your professional information for the organization.

With Gameloft entities

In order to operate the processing describe above, your personal information may be transferred to
other Gameloft studios or entities, subsidiaries, processors or third parties located worldwide.
Gameloft is part of the Vivendi Group and we may share your personal information for audit and
compliance purposes with Vivendi and other Vivendi entities.

With our legal advisors and authorities

In some limited cases there might be the situation when your information could be provided to our
legal advisors, public authorities or court orders when there is a legal base to do so.
In that case, we will consider applicable local laws, the nature of the order, as well as the legitimacy
and proportionality of your information.

For USA, Californian residents, please note to comply with Californian Customer Privacy Act
(CCPA) we do not sell your professional personal information.

7 – Transfer of your personal information

Based on the agreement signed between your company and Gameloft, your acceptance of the
current policy, your personal data might be subject to an international transfer.
Depending the purpose we follow, Gameloft can process your personal information in one or
several countries (for contract signature, if we need to share your information with legal advisors,
authorities…)
We are committed to protect your privacy and we will apply the best available safeguards to protect
your personal information on transfer.

8-Security and confidentiality of your personal information

We have implemented security measures to safeguard and help prevent unauthorized access,
maintain data security, and correctly use the personal information collected through the processing
(on transfer and at rest).
We take, and force applicable third parties to take, reasonable precautions to protect your personal
information against loss, misuse, unauthorized disclosure, alteration, and destruction.
If you believe your personal information is being improperly used by us or any third party, please
immediately notify us via email at DataProtectionSupport@gameloft.com.

9 – Your rights

You can exercise your rights of access, rectification, erasure, restriction of processing, portability,
right to object, right not to be subject to a decision based solely on automated processing, including
profiling by notify us via email at DataProtectionSupport@gameloft.com. We remind you, as data
subject, you have the right to lodge a complaint with a Data Protection Authorities and withdraw
your consent at any point (but please note if the scope where a contract must be fulfilled, this right
might not be applicable.