GRAND CRU PRIVACY NOTICE

Grand Cru Oy (“Grand Cru”, “we”) collects and processes personal data of users of Grand Cru’s online services. This Privacy Notice applies to personal data we obtain from individuals (“Users”) through our websites, online services, and web-based applications (collectively, the “Services").

Our Privacy Notice explains what data we process, how we do that and how the data subjects, i.e. Users, may use their rights (e.g. right to object, right of access).

This Privacy Notice may be updated if required to reflect the changes in data processing practices or otherwise. The current version can be found at http://legal.grandcrugames.com/privacy.html

This Privacy Notice only covers data processing carried out by Grand Cru.

Your privacy, security and online safety are important to us, and we process all personal data with due care and in accordance with applicable laws and regulations.

We understand the need to provide extra privacy protections to users who are children. Please see the section 2 for our Notice regarding children.

For questions and information about Privacy Notice and data subject's rights, please contact us at:

Grand Cru Oy, Kaisaniemenkatu 2b, 00100 Helsinki, Finland.

https:/grand-cru.helpshift.com

www.grandcrugames.com

1. PERSONAL DATA PROCESSED AND SOURCES OF DATA

We collect two types of information from the Users: (i) User Data; and (ii) Technical Data. Although we do not normally use Technical Data to identify individuals, sometimes individuals can be recognized from it, either alone or when combined or linked with User Data. In such situations, Technical Data can also be personal data under applicable laws and we will treat the combined data as personal data.

Grand Cru collects and processes for example the following User Data from Users:

· advertising id

· IP address (location, fraud prevention)

· general location based on IP address

· data about your mobile device, such as device name, operating system, hardware type, language

data about your usage of the game, such as character progression data and interactions in the game

In addition, you may voluntarily submit following data:

· player name

· preferred language

· messages to the service (such as chat logs and player support tickets)

or other data you choose to give us (such as data to identify a lost account)

Technical Data includes typically the following data:

· User’s IP address;

· preferred language;

· geographic location using IP address;

· mobile device ID, hardware type and operating system;

· areas of our Services User have visited

Data on player's interactions and progression within the game:

· transactions with in-game currencies

· hero inventory and hero progression

· player profile progression

· battle history

· UI interactions

· interactions with guilds and friends

2. OUR NOTICE REGARDING CHILDREN

We are a general audience service directed to and intended for users 13 and over. Grand Cru will not knowingly collect personal information from anyone under the age of 13..

In the event that we learn that we have collected personal information from a child under the age of 13, we will delete that information as quickly as possible. If You believe that we might have any information from or about a child under the age of 13, please contact us at contact@grandcrugames.com.

3. PURPOSES AND LEGITIMATE GROUNDS FOR PROCESSING OF PERSONAL DATA

Purposes

We process personal data for the following purposes:

To provide our Services and carry out our contractual obligations

We process personal data in the first place to be able to offer the Services to Users and to run, maintain and develop our business. In some cases, personal data may be processed in order to carry out our contractual obligations towards the User. We may use the data for example to offer essential functionalities of the Services and to provide access to the Services. If User contacts our customer service, we will use the provided information for answering questions and solving possible issues.

For customer communication

We may process personal data for the purpose of contacting Users regarding our Services and to inform Users of changes in our Services. Data may also be used for research and analysis purposes in order to improve our Services.

For quality improvement and trend analysis

We may process information regarding the use of the Services to improve the quality of our Services e.g. by analyzing any trends in the use of our Services. When possible, we will do this using only aggregated, non-personally identifiable data.

Legitimate grounds for processing

We process personal data to perform our contractual obligations towards Users, to serve the game, and to comply with legal obligations. Furthermore, we process personal data to pursue our legitimate interest to run, maintain and develop our business.

In some parts of the Services, Users may be requested to grant their consent for the processing of personal data. In this event, Users may withdraw their consent at any time.

4. TRANSFER TO COUNTRIES OUTSIDE EUROPE

We have operations, entities, and service providers in several geographical locations. As such, we and our service providers may transfer personal data to, or access it in, jurisdictions outside the European Economic Area or the User’s domicile. We will take steps to ensure that Users’ personal data receives an adequate level of protection in the jurisdictions in which we process it.

We provide adequate protection for the transfer of personal data to countries outside of the European Economic Area through a series of intercompany agreements and agreements with our service providers based on the Standard Contractual Clauses or other similar arrangements such as Privacy Shield for data transfers to USA.

5. RECIPIENTS

We only share personal data within the organization of Grand Cru if and as far as reasonably necessary to perform and develop our Services.

We do not share personal data with third parties outside of Grand Cru’s organization unless one of the following circumstances applies:

It is necessary for the purposes set out in this Privacy Notice

To the extent that third parties need access to personal data to perform the Services, Grand Cru has taken appropriate contractual and organizational measures to ensure that personal data are processed exclusively for the purposes specified in this Privacy Notice and in accordance with all applicable laws and regulations.

For legal reasons

We may share personal data with third parties outside Grand Cru’s organization if we have a good-faith belief that access to and use of the personal data is reasonably necessary to: (i) meet any applicable law, regulation, and/or court order; (ii) detect, prevent, or otherwise address fraud, security or technical issues; and/or (iii) protect the interests, properties or safety of Grand Cru, our Users or the public in accordance with the law. When possible, we will inform Users about such transfer and processing.

To authorized service providers

We may share personal data to authorized service providers who perform services for us (including data storage, sales, marketing and customer support services). Our agreements with our service providers include commitments that the service providers agree to limit their use of personal data and to comply with privacy and security standards at least as stringent as the terms of this Privacy Notice. Please bear in mind that if you provide personal data directly to a third party, such as through a link on our website, the processing is typically based on their policies and standards.

For other legitimate reasons

If Grand Cru is involved in a merger, acquisition or asset sale, we may transfer personal data to the third party involved. However, we will continue to ensure the confidentiality of all personal data. We will give notice to all Users concerned when the personal data are transferred or become subject to a different privacy notice as soon as reasonably possible.

We may share personal data with third parties outside Grand Cru’s organization for other reasons than the ones mentioned before, when we have the User’s explicit consent to do so. The User has the right to withdraw this consent at all times.

6. STORAGE PERIOD

Grand Cru does not store personal data longer than is legally permitted and necessary for the purposes of providing the Services or the relevant parts thereof. The storage period depends on the nature of the information and the purposes of processing.

Typically, we will store User’s personal data for as long as the User is a registered subscriber or a registered user of our Services or for as long as we have another purpose to do so and, thereafter, for no longer than is required or permitted by law or reasonably necessary for internal reporting and reconciliation purposes.

In general, personal data of Users are deleted within reasonable time after the User no longer uses any part of the Services or when the User makes a request regarding deletion of User’s personal data. In any case we will not store data for longer period than ten (10) years unless there is a mandatory legal requirement or binding court order.

7. USERS’ RIGHTS

Right to access

As a User you have the right to access your personal data that is processed by Grand Cru. This means that Users may contact us and we will inform what personal data we have collected and processed regarding the said User and the purposes such data are used for.

Right to correct

You have the right to have incorrect, imprecise, incomplete, outdated, or unnecessary personal data we have stored about you corrected or completed.

Right to deletion

You may also ask us to delete your personal data from our systems. We will comply with such request unless we have a legitimate ground to not delete the data. We may not immediately be able to delete all residual copies from our servers and backup systems after the active data have been deleted. Such copies shall be deleted as soon as reasonably possible.

Right to object

You may object to certain use of personal data if such data are processed for other purposes than purposes necessary for the performance of our Services to you or for compliance with a legal obligation.

You may also object any further processing of personal data after prior given consent. If you object the further processing of personal data, this may lead to fewer possibilities to use our Services.

Notwithstanding any consent granted beforehand for the purposes of direct marketing, you have the right to prohibit us from using your personal data for direct marketing purposes, market research and profiling by contacting us on the addresses indicated above or by using the functionalities of the Services or the unsubscribe possibility offered in connection with any direct marketing messages.

Right to restriction of processing

You may request us to restrict certain processing of personal data, this may however lead to fewer possibilities to use our Services.

8. LODGING A COMPLAINT

In case you consider our processing of personal data to be inconsistent with the applicable data protection laws, you can lodge a complaint with the local supervisory authority of data protection.

You can find your data protection authority contact information in EU here: https://ec.europa.eu/info/law/law-topic/data-protection/reform/rights-citizens/redress/what-are-data-protection-authorities-dpas-and-how-do-i-contact-them_en

9. INFORMATION SECURITY

We have taken administrative, organizational, technical, and physical safeguards to protect the personal data we collect and process. Our security controls are designed to maintain an appropriate level of data confidentiality, integrity, and availability. We regularly test our websites, data centers, systems, and other assets for security vulnerabilities.

10. FURTHER INFORMATION

This Privacy Notice is governed by Finnish law excluding its choice of law provisions.