GENERAL PERSONAL DATA PROTECTION POLICY

Focus Entertainment Publishing – Entry into force of the latest update: 31 July 2024

Focus Entertainment Publishing (hereinafter “We” or “our” or “Focus Entertainment”) pays the utmost attention to the protection of your personal data (hereinafter “the Data” or “your Data”) and to the respect of your privacy. You will find in this General Personal Data Protection Policy (hereinafter the “Policy” or “GPDP”) transparent information relating to the protection of your Data collected and processed by Focus Entertainment through its Websites.

 In accordance with its legal obligations, and in order to ensure the proper application of these rules, Focus Entertainment Publishing has appointed a Data Protection Officer (DPO) who you can contact:

·        by email at the following email address: personaldata@focusent.com; or

·        by post: Focus Entertainment Publishing, Parc du Pont de Flandre, Bâtiment 28 “Le Beauvaisis”, 11 rue de Cambrai, 75019 PARIS.

SUMMARY

 1.      How do we collect your Data?

2.      For what purposes do we collect your Data and how long do we keep it?

3.      With whom does Focus Entertainment share my Data?

4.      What are my rights and how do I exercise them?

5.      Transfer of your Data outside the European Economic Area

6.      How does Focus Entertainment protect your Data?

7.      Minors

8.      Hypertext links to other websites

9.      GPDP Change and Update

DEFINITIONS

 Store: refers to the online store accessible via the address https://store.focus-entmt.com/ offering for sale the products published by Focus Entertainment (games and derivatives).

Focus Together Account: means the personal user account opened by a User to make use of the Products and Services made available on the Websites.

Customer: means any User who has made a purchase on the Store.

Personal Data or Data: means information, in any form whatsoever, directly or indirectly relating to an identified or identifiable natural person.

Community Platform: refers to Focus Entertainment’s community interface, accessible via https://community.focus-entmt.com/, where users can contribute.

Player: means any Customer who has made a purchase in the Store or accesses the games published by Focus Entertainment, and/or any User participating in test programmes (Beta and Playtests) in the TestZone.

Products and Services: refers to all products and services accessible via the Focus Together Account whose terms of use are defined in the General Terms and Conditions of Use (“GCU”).

Partners: refers to Focus Entertainment’s business and commercial partners, including external development studios.

Data Controller or Focus Entertainment: refers to the company FOCUS ENTERTAINMENT PUBLISHING, a société par actions simplifiée [simplified joint-stock company] registered under No. 898 472 170 in the Paris Trade and Companies Register, whose registered office is located at Parc du Pont de Flandre, Bâtiment 28 “Le Beauvaisis”, 11 rue de Cambrai, 75019 PARIS (France), and which, alone or jointly with others, determines the purposes and means of processing the Data.

Processor: means any company that processes Data on behalf of the Data Controller.

Website(s): refers to the websites published and operated by Focus Entertainment Publishing, accessible via the address https://www.focus-entmt.com/fr, including websites that allow access to the Community Platform, TestZone and the Store.

TestZone: refers to the platform accessible via the address https://testzone.focus-entmt.com/ allowing Users to register and participate in test programmes (Beta and Playtests) especially on games under development.

User: means any Visitor who creates a Focus Together Account to access the Products and Services made available on the Websites.

Visitor: refers to any adult natural person who accesses the Websites.

GENERAL INFORMATION

We collect some of your Data via our video games and/or Websites, in particular to provide you with Products and Services accessible on our Websites:

• Create and use your Focus Entertainment Account;

• Buy the products published by Focus Entertainment in our Store;

• Participate in the test phases of our games;

• Sign up for our newsletter to receive information about Focus Entertainment games, sales offers and promotions, surveys, competitions and Beta tests;

• Participate in the Forum and the competition games.

We mainly collect identifying information and information about your use of our services. The categories of information we collect in connection with your use of our games, products and services, the corresponding purposes and legal bases are described in the table provided for in Section 2 of this Policy.

1. How do we collect your Data?

 We collect certain Data through our video games and/or Websites in order to provide you with the best possible experience regarding the use of our Products and Services, but also for marketing purposes with your consent.

 The categories of Data we collect in connection with your use of our Products and Services are described in the table provided for in Section 2 below.

1.1   Direct collection

Focus Entertainment collects your Data directly in the following cases:

• When browsing our Websites and using the Products and Services, when:

  • You enter your date of birth in the pop-up window to check your age;

  • You create, complete and use your Focus Together Account, including to access related services (in particular the Community Platfom);

  • You choose to publicly share when you use the Community Platfom;

  • You sign up for the Newsletter;

  • You win in our competitions organised on our official profiles on social networks;

  • You sign up for the test phases of the games we offer (Betas and Playtests);

  • You consent to the use of cookies and other tracers (as described in our policies on cookies accessible on our Websites).

• When you use our video games, when:

  • You access certain games offering online features (multiplayer games, ranking systems, cross-platform backups);

  • You consent to the analysis of your game data as part of your use of video games on which telemetry is activated.

The mandatory or optional nature of the Data collected directly by Focus Entertainment is indicated with an asterisk when collected. Please be aware that if you refuse to enter certain Data, the collection of which is mandatory, you may not be able to benefit from all or part of the services offered.

 1.2   Indirect collection

Focus Entertainment collects your Data indirectly in the following cases:

• The purchase of our products in the Store, managed by our reseller partner (see its privacy policy here);

• Your access to, or use of, some of our games and derivatives available on certain social networks, platforms and consoles, or other third-party websites (hereinafter collectively the “Third-Party Websites”).

 Please note that this Policy does not apply to the processing carried out independently by Third-Party Websites and we do not control their respective privacy practices. We recommend that you carefully read the privacy policies available on each of these Third-Party Websites, in particular regarding the sharing of your Data.

 Focus Entertainment will process the Data received indirectly under the terms and conditions provided for in this Policy.

2. For what purposes do we collect your Data and how long do we keep it?

*For all processing based on your consent, you are informed that you can withdraw it at any time, at no cost. For example, you may withdraw your consent for the sending of commercial / marketing communications by Focus Entertainment, if applicable:

• by clicking at any time on the “Unsubscribe” link in each email,

• by disabling the corresponding box in the preferences of your Focus Entertainment Account if you have one; or

• by contacting us following the procedure described in section 4 below.

** "Customer match" is a way to create an advertising audience using user's e-mail address. We share with our partners (such as Facebook, Google or Twitter/X) a list of hashed e-mails and they compare with their users. If there is a match, the user is added in an audience pool. If you accept "customer match", you give us the authorization to share your hashed e-mail with our partners in order to display personalized ads on their websites.

The Data collected are kept only for the time necessary to achieve the objective pursued during their collection (so-called “active” use) and in accordance with the applicable laws.

Focus Entertainment may retain your Data for longer periods, in intermediate archiving (separate from the active base and with restricted access), when justified: for the exercise of our legal obligations (limitation period) and/or the protection of our rights (foreclosure period), particularly in commercial, civil and tax matter, i.e. a maximum of 10 years; but also in the event of litigation during the entire duration of the proceedings and up to 10 years from the execution of the final decision.

Once these deadlines have expired, we will delete or anonymise your Data.

3. With whom does Focus Entertainment share my Data?

Communication of your Data to our service providers and suppliers

As a video games publisher, certain Data we collect may be communicated and/or shared with: our development studios, our law firms and technical and IT service providers or our suppliers. Where appropriate, communication and/or sharing is carried out for technical and operational purposes, to enable us to offer you high-performance games, provide you the requested products and/or services.

In all cases, we implement the necessary contractual and organisational measures so that the processing of your Data by these third-party providers is strictly limited to the purposes defined in this Policy and to guarantee the confidentiality and security of your Data.

Communication of your Data by our partners

Some partners may need to request your consent for the collection of Data in our video games, on their own behalf. This Policy does not apply to such processing implemented by these partners, acting as independent controllers. We recommend that you carefully read the privacy policy of each of these partners.

4.What are my rights and how do I exercise them?

You have all of the following rights to the Data about you that we collect and process:

• Right to access your Data: you have the right to obtain (i) confirmation that your Data are or are not processed; when they have been processed, (ii) access to these Data and (iii) a copy of the Data processed by Focus Entertainment, in an understandable format;

• Right to request the modification, updating or rectification of your Data when you consider it inaccurate, incorrect or incomplete;

• Right to request the deletion of your Data for the reasons provided for by the applicable regulations;

• Right to limit the processing of Data concerning you for the reasons provided for by the applicable regulations;

• Right to object to the processing of your Data if we use your Data:

  • For our legitimate interests;

  • For statistical purposes; or

  • For commercial prospecting (marketing) purposes.

• Right to withdraw your consent at any time when the processing is based on your consent (it being recalled that this withdrawal will not affect the lawfulness of the processing, based on consent, carried out before its withdrawal);

• Where appropriate, the right not to be the subject of a decision based exclusively on automated processing, including profiling, producing legal effects concerning the data subject or affecting the latter significantly in a similar way. Right to the portability of your Data: this right applies to the Data that you have transmitted to us when the processing is automated and based on your consent or carried out on the basis of the performance of a contract. You have the right to ask us, if technically feasible, to transfer your Data to a third party or to provide them directly to you in an accessible and machine-readable manner;

• Right to transmit instructions regarding the storage and communication of your Data after your death;

• Right to lodge a complaint with the CNIL if you consider that we do not comply with our obligations with regard to your Data. You can send a complaint or request electronically at any time by clicking on the following link: https://www.cnil.fr/fr/plaintes/internet.

To exercise your rights, you can send your request by specifying the right(s) concerned and the reasons for your request, if applicable:

• by email at the following email address: personaldata@focusent.com; or

• by post: Focus Entertainment Publishing, Parc du Pont de Flandre, Bâtiment 28 “Le Beauvaisis”, 11 rue de Cambrai, 75019 PARIS.

We will acknowledge receipt of your request as soon as possible and, if it is admissible, we will provide you with the requested information or implement the rights invoked within one month.

If, given the complexity of the request or the number of requests received, the aforementioned period of one month cannot be respected, we will inform you before the expiry of said period of the postponement of our decision, but not beyond a further two-month period.

In the event of manifestly abusive requests (in particular due to their number, repetitive or systematic nature), Focus Entertainment will be entitled not to respond to them. If applicable, we will inform you of the reasons for our refusal.

Requests for the exercise of rights are processed by the authorised teams of Focus Entertainment as data controller, in connection with those of PulluP Entertainment, our parent company, as data processor.

5. Transfer of your Data outside the EEA

 Focus Entertainment may transfer some of your Data outside the European Economic Area (EEA), for technical and operational purposes, to enable us to offer you high-performing games and to provide you with the requested services. These transfers are carried out in accordance with applicable data protection regulations and transfer management solutions recognised by the GDPR.

 In particular, when the transfer of your Data cannot be carried out on the basis of an adequacy decision of the European Commission recognising an adequate level of protection, we put in place other appropriate transfer mechanisms and safeguards to ensure the protection of your Data, in particular data transfer agreements including standard contractual clauses approved by the European Commission in their version in force at the time of the transfer concerned, or other device recognised by this regulation, including the new EU-US Data Protection Framework.

For more information on the safeguards related to the transfer of Data, you are invited to contact us at the following address: personaldata@focusent.com.

6. How does Focus Entertainment protect your Data?

We implement all appropriate technical and organisational measures to ensure the security, confidentiality and integrity of your Data and to protect your Data against accidental or unlawful destruction, accidental loss, damage, modification, disclosure or unauthorised access, as well as against any other form of unlawful processing.

As an example and without this list being exhaustive, we maintain:

• an authentication system to protect access to your online accounts;

• hashing procedures for some of your Data;

• limited access (authorisation policy) to only employees and/or processors of Focus Entertainment who need to know it due to their duties, when required to provide our services to you and subject to strict confidentiality obligations; etc.

We regularly set up security checks and may in this regard temporarily suspend our services in case of suspicion or detection of a security breach. If you have any concerns about the security of your Data, you can contact us at the following address: personaldata@focusent.com.

7. Minors

 Minors under the age of 18 cannot directly subscribe, purchase and/or use the services offered by Focus Entertainment.

 We verify your age by asking you to enter your date of birth in a dedicated pop-up window on the Website in our Store. If you are under the age of 18, you will not be able to visit the pages of the Store or create a Focus Entertainment Account and therefore access the Products and Services accessible on our Websites.

 Focus Entertainment does not intentionally collect Data from minors under the age of 18. If we realise that we have collected Data concerning a minor within the meaning of the applicable data protection regulations, we will immediately delete any Data concerning this minor.

8. Hypertext links to other websites

 Our Websites may contain hyperlinks to Third-Party Websites. Since we have no control over these Third-Party Websites, we may not be held liable for the processing and confidentiality of Data transmitted on websites that we do not publish.

 The Data and information communicated through these hyperlinks are the responsibility of their respective publishers. We therefore recommend exercising caution when browsing Internet pages accessible via hyperlinks.

9. GPDP Change and Update

We periodically review this Policy to ensure compliance and keep it up-to-date with the applicable data protection regulations.

 Before browsing, we invite you to refer to the latest version of the Policy. You can find out if there have been any changes since your last visit by checking the date at the top of the page.