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 1, 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 a business relationship or plans to begin a relationship with your Company. Gameloft needs to collect and process some professional personal information from you or from other Representatives in your company or from 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 Gameloft operates
Resolution of disputes, investigations or any other petitions/complaints to which Gameloft is party
To negotiate, execute, modify or terminate the agreement; and offer, activate and provide services
Analyze and respond to complaints
Detect and prevent fraud
Video recording of data subjects at physical Gameloft locations in order to maintain a high level of security
Specific purposes stated in the documentation relating to the different types of contract products by the company (e.g. specific terms and conditions per product)
The archiving of documents (paper or electronic) between Gameloft and the Company, in some limited cases, needed to perform internal or external audit activities on Gameloft
The possibility of using Gameloft tools (or applications) in some limited cases as defined in the agreement between Gameloft and the Company
The conduct of direct marketing activities involving the communication of promotional materials and offers through electronic means of communication (telephone, email, SMS, etc.) or by post, with respect to Gameloft services and products

3 – Legal basis for processing personal data

Gameloft processes the data for the above purposes based on the following legal grounds:

Legitimate interest of Gameloft
For the conclusion and performance of a contract (including prior to entering into an agreement)
With 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 the identification data included in documents attesting to the function occupied within the Company's organization (e.g. name, surname, signature)
The position occupied within the Company's organization
Limited personal information Gameloft may access (or receive) from authorities in accordance with applicable money laundering and terrorist financing regulations
Professional contact details: email address, fixed/mobile phone, fax
Video recordings if you visit our studios or business offices

b – Information we may automatically collect directly from you when you log in to 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 on your device settings
Name and professional email address
Account credentials
Cookies (depending on the website/application used); please refer to the 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 applicable laws. We want to inform you that a longer retention period could be required to resolve disputes, or answer regulatory or police requests. 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 may organize internal or external events with third parties. These third parties may have access to your professional information for the organization of these events.

With Gameloft entities
In order to conduct the processing described above, your personal information may be transferred to other Gameloft studios or entities, subsidiaries, processors, or third parties 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 may arise a situation in which your information must be provided to our legal advisors, and we may also disclose your information to public authorities 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.

For residents of California, USA, please note that, in compliance with the California 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, and your acceptance of the current policy, your personal data might be subject to an international transfer.

Depending on the purpose of the transfer, 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, etc.).
We are committed to protecting your privacy and will apply the best available safeguards to protect your personal information upon transfer.

8 – Security and confidentiality of your personal information

We have implemented security measures to safeguard your information and help prevent unauthorized access, maintain data security, and correctly use the personal information collected during processing (in transit 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, and right not to be subject to a decision based solely on automated processing (including profiling) by notifying us via email at DataProtectionSupport@gameloft.com. We remind you, as a data subject, that you have the right to lodge a complaint with a Data Protection Authority.

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 (including, but not limited to, U.S. and EU export control authorities).