GAMELOFT PRIVACY POLICY

--- Gaming operations-related ---

CARMEN SANDIEGO (mobile)

This Privacy Policy is effective as of October 17, 2025, and intended for the mobile game CARMEN SANDIEGO (the “Game”) published by Gameloft SE.

In summary, the Game is accessible by subscription. It does not include any features that enable advertising, advanced tracking, in-app purchases, or access to social networks. The collection of personal data is limited to what is necessary to provide the service and perform basic analyses as a publisher. We do not share information with third parties, except when you connect to Google Play or iOS Game Center for authentication purposes.

Introduction

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 describes what information Gameloft collects and how we use, disclose, transfer, and store it when you play our games.

Gameloft SE, including its subsidiary companies (“Gameloft”), collects, stores, and uses your information as a data controller within the meaning of the General Data Protection Regulation (Regulation [EU] 2016/679; “GDPR”) and a Business within the meaning of the California Consumer Privacy Act of 2018, as amended and expanded by the California Privacy Rights Act of 2020 (collectively, the “CCPA”), in connection with, and in order to provide and develop, Gameloft’s games (including the Game), loyalty program (Gameloft Club), mobile applications, services and websites (together referred to as the “Services”) in accordance with this privacy policy (“Privacy Policy”).

All of our Services related to gaming operations, whether used on mobile devices, PCs or other platforms, are governed by this Privacy Policy.

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

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 – How we collect your information

Gameloft collects some information from you when you:

(a) create an account;

(b) get a subscription to play our games;

(g) sign up for a newsletter;

(h) contact Gameloft customer service and take part in technical-support sessions;

(i) enter a contest, event or sweepstakes, or participate in a challenge held by Gameloft;

(k) signal interest in participating in a playtest;

2 – Information we collect

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

a – Information you provide us with

Contact information (such as your name and email address when you create an account or subscribe to the newsletter)
Profile information (such as a profile picture)
Information that you provide when seeking help from our customer service (such as chat logs, contact details such as your phone number and email address if necessary to resolve your request, customer support tickets, personal identification documents in order to verify your identity or age)
Other information you may provide us with (such as information used to identify a lost account)

b – Information we collect from you when you use our Services

Information about your game progress and activity to provide you with support and perform basic analytics (statistics)
IP address to facilitate communication and determine coarse location

Information about your device (such as device name and operating system, browser information, including browser type and the language you prefer)
Information we collect using cookies and similar technologies, knowing that we only use these technologies for purposes that do not require your consent, as they are essential to the provision of the Service (you can refer to our Cookies Policy to learn more about such technologies)
Gameloft player ID (internal to Gameloft and never shared with third parties)

c – Information we obtain from our partners

Information that we receive if you decide to connect from the stores (Google Play or iOS Game Center)

d – Information we DO NOT collect

As part of its commercial Services, Gameloft does not collect sensitive information, such as personal data revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, trade-union membership, genetic data, biometric data processed solely to identify a human being, health-related data, data concerning a person’s sex life or sexual orientation, credit or financial data.

3 – How we use your information

We only collect personal information from you when:

we have a legal obligation to collect and process personal information from you (when you contact customer support to exercise your rights, when we answer any requests from Data Protection Authorities or any law enforcement agency)
we have your consent to do so (when we process your email address to send you newsletters)
we need the personal information to fulfill a contract with you and provide you with the Services (when we process your credentials to access a Service you subscribed to; when you participate in a contest or win a prize; when you contact customer support services; when we carry out debug, service-error detection, and fraud prevention)
the processing is in our legitimate interests (when we measure the effectiveness of content displayed based on statistics or aggregated data without infringing on your fundamental rights).

4 – How we retain your information

Gameloft retains, uses and stores your information as long as you are playing our games or using our Services, and also for the period necessary to fulfill all the purposes described in this Privacy Policy, in compliance with the applicable laws of your country of residence. 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.

5 – 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 "International operations and transfers of your information").

With third parties

We use third-party services that have limited access to your information for specific purposes, such as:

Hosting (AWS and Google Cloud Platform) and customer service support (Helpshift)
Game connection from stores (Google Play or iOS Game Center)
Participating in a survey or a contest, when we deliver you a prize, provide you with marketing assistance or send newsletters at your request

Such third parties are only authorized to use your information for the purposes specified in the agreement we entered into with each of them. Note that this data sharing is subject to your prior consent via a specific checkbox (for newsletter, contest, survey or prize award purposes, for example).

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 may also 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.

6 – 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 SE) 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 will receive an adequate level of protection in the jurisdictions in which we process it.

7 – 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 ensure 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.

8 – Children

We encourage parents and guardians to teach their children about privacy and how their information may be used on the Internet. Children should never disclose their name, address or phone number, or any personal information, without their parents’ or guardian’s prior permission.

We consider a user to be a child if they are under the age of 13, unless more stringent regulation applies in their state of residence.

If we consider that any of our Services are directed at users under the minimum legal age required in their country of residence, we can block such users from using the Services or from providing information and/or limit the collection of information from such users as described below in more detail.

No personal information should be submitted to Gameloft by users under the minimum legal age required in their state of residence. We apply the following limitations to personal information collection for a user that is not of the minimum legal age required in their state of residence.

Such a user cannot:

display their real name or any information in the games
access the chat, leaderboard, forums, SNS (Discord, Game Center, etc.) when they are made available
subscribe to newsletters
use any other feature where users could appear under their real names

Children can be invited to take part in testing our games (playtests) with their parents' or guardians’ authorization and/or their parents' or guardians’ physical presence being required depending on the state where the playtest is conducted.

Parents must exercise their privacy rights for their children. Please refer to the "Your rights regarding personal data" section of this Privacy Policy.

If you want to find out more about the privacy and security practices Gameloft implements to protect children, please read the Privacy Policy for Parents.

9 – [Intentionally left blank]

10 – Your rights regarding personal data

You can exercise your rights at any time by accessing this form or by sending your request to DataProtectionSupport@gameloft.com.

If you are the 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 the form.

If you are a Californian user, please refer to the "11 – Additional information for U.S. users" section of this Privacy Policy.

As a user, you have certain rights regarding your personal data, depending on applicable data protection laws. These rights may include:

Right to Be Informed (“Right to Know”) – You have the right to know how we collect, use, store, and share your personal data. This Privacy Policy provides that information. You can contact DataProtectionSupport@gameloft.com if the information you are looking for is not mentioned in this Privacy Policy.
Right to Withdraw Consent – If you want to change your choices regarding the use of tracking technologies (such as cookies and SDKs) and the collection and processing of personal data, you can do so as follows:
- Website: Go to the “Manage Your Choices” tab at the bottom of the page
- Application: Go to your settings and select “Manage my choices”
- Newsletter: To unsubscribe from a Gameloft newsletter, you can use the link at the bottom of the email you received
Right to Erasure (“Right to be Forgotten” or “Right to Deletion”) – You can request the deletion of your personal data that we store.
Right to Restrict Processing – You have the right to limit how we use your data in certain situations.
Right to Access – You can request a copy of the personal data we hold about you.
Right to Data Portability – The personal information we have is only related to the Gameloft games or Services you use. This information is not portable, and it cannot be reused in other games or systems.
Right to Rectification (“Right to correct”) – We ask that you keep the information that you provide to us updated. You can correct any information you have provided. You represent and warrant that all information you provide us is true and correct, and relates to you and not to any other person.
Right to Object – You have the right to object, at any time, to processing of your personal data for marketing purposes, which include profiling. By unsubscribing from the newsletter, you will object to profiling at the same time. To proceed, you can follow the process described in the “Right to Withdraw Consent” section above.
Right to Oppose Profiling and Automated Decision-Making – Gameloft does not carry out any profiling based on automated decision-making that would have a legal effect on the user. Therefore, it is not possible to exercise this right.

Account deletion button

We provide an in-app account deletion option in compliance with the requirements set by the Apple App Store and Google Play Store. Users can request the permanent deletion of their account directly within the app through the account settings.

When you delete your account:

All personal data associated with your account, including profile information, saved preferences, and linked services, will be permanently removed unless retention is required by law.
Any in-game progress, virtual currency, or purchased content, if any, may be lost and cannot be recovered.

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

Your actions may force Gameloft to cease 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 game or game 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 game or game Services).
If you withdraw your consent, we will not use or process your information anymore.

If you ask for deletion of your information, the data associated with your account will be deleted. This is an irreversible process that cannot be interrupted once launched. All your in-game progress, any purchases you may have made, achievements, leaderboard positions and in-game friends in these games will be lost. Please note that we are not required to comply with your request to erase personal information if the processing of your personal information is necessary for compliance with a legal obligation or for the establishment, exercise or defense of legal claims.
Note that for the consent withdrawal and deletion processes, we may store your information to answer regulatory or police requests if deemed necessary. Certain personal data may be retained despite a right to be forgotten request where legal, regulatory, or overriding legitimate grounds require preservation.

Our team will investigate your request and answer you within 30 days, unless your request requires further investigation. You’ll be specifically informed if that is the case.

If you believe that your rights have not been upheld after contacting us, or if you believe that your rights have been violated, you have the right to file a complaint with the data protection authority in your country or to notify them of the violation:

11 – Additional information for U.S. users

U.S. privacy regulations provide the users with the rights described above and with specific other rights. If you are a U.S. user, please access this form or refer to the “How to contact us” section of this Privacy Policy to exercise your rights.

Note that the Game does not perform targeted advertising (neither contextual nor basic advertising) and does not share personal information with third parties for commercial purposes. Therefore, the obligation to provide a “Do Not Sell/Share My Personal Information” link, as defined by the CCPA in California, does not apply.

12 – Third-party services

The Services may link to external sites that are beyond our control. This Privacy Policy only covers the way we treat personal information and non-personal information we collect on the Services. By accessing any external sites, you agree to the privacy policies of those sites. Please understand that external sites may have different policies with respect to the collection, use and disclosure of your personal information. We have no control over, and are not responsible for, the privacy practices of such third parties.

Therefore, you are encouraged to review the privacy policies of all third-party services. Without limiting anything in the following section, we are not liable in any way for the actions, inactions or policies of any external services.

13 – 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.

14 – 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 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.

15 – 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