GAMELOFT PRIVACY POLICY
GAMES AVAILABLE ON APPLE ARCADE

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 Policy is specific to Gameloft games offered on Apple Arcade. It describes what information Gameloft collects and how we use, disclose, transfer, and store it (when necessary). If you do not want Gameloft to collect, store, use or share your information in the ways described in this Privacy Policy, you may not be able to use our Services (as described below).

Gameloft S.E, including its subsidiary companies (“Gameloft”), collects, stores, and uses your information as a data controller in connection with, and in order to provide and develop, Gameloft’s services and websites (together referred to as the “Services”) in accordance with this privacy policy (“Privacy Policy”).

All of our Services available on Apple Arcade, whether used on mobile devices, Mac or other platforms such as Apple TV, are governed by this Privacy Policy.

By using the Services, you hereby consent to this Privacy Policy.

This Privacy Policy is effective as of August 18, 2019, and was last modified on August 20, 2019.

If you have any questions, comments or concerns regarding our Privacy Policy and/or practices, please see the “How to contact us” section below.

1 – Information we collect from you – purposes and uses

Our game is available on Apple Arcade.

Gameloft collects only adequate, relevant and limited information from you when you: (a) need help from our Customer Care, or (b) exercise your privacy rights.

Gameloft Customer Care uses your information only to answer your requests regarding any game issue or your privacy rights.

For these purposes, you provide us with your contact information directly (such as your name, email address, phone number, country and language).

2 – Information collected from your use of the game – purposes and uses

Information is collected through your use of the game and stored on Apple services, such as iCloud for game saves and Game Center for achievements, leaderboards, and multiplayer. Except as specially provided in Section 1, we do not store personal or gameplay data on our servers.

3 – How we retain your information

Gameloft retains, uses and stores your information to fulfill all the purposes described in this Privacy Policy, for no more than one hundred eighty (180) days after you use our Services.

4 – How we share your information

With Gameloft entities

In order to operate the Services, your personal information may be transferred to other Gameloft studios or entities, subsidiaries, processors or third parties located worldwide as described below (please refer to the "International operations and transfers of your information" section).

With service providers

We use service providers for the specific purposes described above. They assist us with our operations.

Such providers are authorized to use your information for these purposes. They only have limited access to your information.

With authorities

We reserve the right to report to law enforcement agencies activities that we, in good faith, believe to be illegal. We will investigate or take action to counter illegal activity, suspected abuse or unauthorized use of the Services, or to protect the property or safety of others. We also may disclose your information if required by any law or court order worldwide, if the information relates to actual or threatened harmful conduct.

In that case, we will consider applicable local laws, the nature of the order, as well as the legitimacy and proportionality of your information.

In case of sale of our company

In connection with any sale of our company or any line of business (including the assets relating thereto), customer information generally is one of the transferred business assets. In the event of any such sale or disposition of any or all of our business, your information may be transferred to the acquirer.

5 – International operations and transfers of your information

As part of our international operations, we may transfer personal information to our affiliates (which means subsidiaries, parent companies, joint ventures, and other corporate entities under common ownership of Gameloft S.E) from time to time for our legitimate business purposes.

Gameloft is headquartered in France, and we have operations, entities and Services provided in Canada, the United States and throughout the world. We have taken measures to ensure that your personal information is treated securely and lawfully, and that it receives an adequate level of protection in the jurisdictions in which we process it. If you are located in the European Economic Area (“EEA”) or Switzerland, we provide adequate protection for the transfer of personal information to countries outside of the EEA or Switzerland based on the standard contractual clauses authorized by the European Commission or other appropriate safeguards defined in Article 46, General Data Protection Regulation (GDPR) (EU) 2016/679.

6 – 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 Services. We take, and force applicable third parties to take, reasonable precautions to protect your personal information against loss, misuse, unauthorized disclosure, alteration, and destruction. However, please remember that no transmission of data over the Internet or any wireless network can be guaranteed to be 100% secure. As a result, while we strive to protect your information, we cannot guarantee the security of your information and do not assume any responsibility for the unauthorized use of, or access to, your information that is under our control.

When we use third parties to assist us in processing your personal information or credit card information, we take reasonable steps to require that they comply with this Privacy Policy and otherwise protect your personal information (including any credit card information).

If there is a breach of security involving your personal information, including credit card information, from our Services, we will inform you immediately according to your local regulations relating to the notification of information Breaches, and take commercially reasonable steps to rectify such breach.

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.

7 – Your rights

We ask that you keep the information that you provide to us updated. You represent and warrant that all information you provide to us is true and correct, and relates to you and not to any other person.

You can correct any information you have provided to us by contacting us through this form.

Please note that this form is available to all Gameloft players worldwide and for games for which we carry out more personal data collection and processing than for the games available on Apple Arcade.

So you may exercise any of the rights proposed in this form, at any time, but we may not perform the corresponding personal data processing. We will point this out to you in such cases. In order to fully respond to your privacy request, we may transfer it to Apple (for instance: if you ask that your data be modified or deleted).

Please note that the Services can be affected by your actions. Some of your information and its processing is mandatory for Gameloft to provide the Services.

Your actions can oblige Gameloft to stop providing the Services. When the conditions below apply, your game will be reset:

• If you ask for the modification of this mandatory information, we may not be able to continue to link the Services to you.
• If you request limitations to processing that are mandatory for Gameloft, or you object to such processing (in which case, we may not be able to provide you with the Services).
• If you withdraw your consent or ask for the deletion of your information.

If you withdraw your consent or ask for the deletion of your information, we will not use or process your information anymore but we will store it—for a maximum of one hundred eighty (180) days from the date of your request—to answer regulatory or police requests. We further reserve the right to retain an anonymous version of such information.

Please specify your request through this form.

If you are a parent of a child who is under 13 years of age (or under another age specified by applicable regulations) and believe your child has provided us with information, please fill out this form and we will delete the information from our system.

Our team will look into your request and will answer you within one month, unless your request requires further investigation. You’ll be specifically informed if this is the case.

If you want to decline to permit cookies or other tracking technologies, please read our Cookies Policy on our website. We remind European users that they have a right to lodge a complaint with a European Data Protection Supervisor.

8 – Changes to our Privacy Policy

We reserve the right to change this Privacy Policy at any time. In the event that we make material changes to this Privacy Policy, they will be re-posted in the "Privacy" section of our websites and apps with the date the modifications were made indicated at the top of the page. Therefore, please review this Privacy Policy from time to time so that you are aware when any changes are made to it. Your continued use of the Services after such change(s) constitutes your acceptance of any such change(s), and if you do not accept any changes, you may choose not to use the Services or opt out by sending us appropriate notice. If you would like further information about any recent changes made, please send your request to DataProtectionSupport@gameloft.com and include “Information about Changes” in the subject line.

9 – Legal disclaimer

Our Services operate AS IS, and we do not represent or warrant that our Services will be available at all times, or that your use of the Services will be uninterrupted or error-free. We are not responsible for your ability to access the Services or for matters beyond our control. This Privacy Policy is governed by the laws of your country of residence. Any dispute arising from the use of the Services shall be submitted to the competent courts of your country of residence.

10 – How to contact us

If you have any questions, comments or concerns regarding our Privacy Policy and/or practices, please contact us:

1 – by sending an email to DataProtectionSupport@gameloft.com
2 – by writing to the Gameloft Data Protection Officer, 14 rue Auber, 75009 Paris, France