INTRODUCTION

WELCOME IN THE LOBBY!

HOMA GAMES SAS (hereafter, “Homa”, “us”, “our”, or “we”) makes the respect of privacy and the

protection of personal data a top priority.

For this reason, you will find in this privacy policy (hereafter the “Policy”) all the information you need

to know more about the rules and understand our processing of your personal data whether you are

(hereafter indistinctly “you” or “your”):

a visitor of our websites (i.e., http://homagames.com/, https://homagang.xyz/,

https://academy.homagames.com/ and https://lab-v2.homagames.com/login ; hereafter

the “Websites”) (hereafter the “Visitors”);

a user of any games or mobile applications (hereafter individually the “Games”, or the

“Apps”, together the “Services”) published by Homa (hereafter the “ Players”);

a game developer or representative of studio willing to partner with Homa (hereafter the

“Developers”); or

an applicant to a job position at Homa (hereafter the “Applicants”).

WHO IS THE CONTROLLER OF YOUR PERSONAL DATA ?

IT’S US!

We, HOMA GAMES SAS, a gaming technology lab, registered in France under n°853 547 644 at the Paris

Commercial Registry, headquartered at 7 rue de Madrid, 75008 PARIS (France), act as controller of the

processing of your personal data, as further described in this Policy. It means that we determine the

purposes (why) and the means (how) of the processing of your personal data.

PLEASE CONTACT US

If you have any questions, concerns, or claims regarding this Policy or the processing of your personal

data, don’t get stuck, just contact us:

by sending an email to our Data Protection Officer (hereafter the “DPO”) to the following

address: dpo@homagames.com .

by letter at the following address: Homa, (DPO) 7 rue de Madrid, 75008 PARIS, FRANCE.

HOW IS YOUR PERSONAL DATA COLLECTED?

When you access and/or use our Websites and Services, your personal data is collected (i) directly

and/or (ii) indirectly by Homa.

Pick your character below depending on your relationship with Homa (i.e., Visitor, Player, Developer or

Applicant) (hereafter your “Homa Character”) to find out how your personal data is being collected.

PICK YOUR HOMA

CHARACTER

YOUR PERSONAL DATA IS

DIRECTLY COLLECTED

YOUR PERSONAL DATA IS

INDIRECTLY COLLECTED

I AM A

VISITOR

We directly collect your

personal data when you:

• send us an email.

We use cookies to collect your personal

data from your device when you use

or access our Websites. Find more

information on this matter in Section 9

below “Do we use cookies?”

I AM USER

We directly collect your

personal data when you:

• create your Player

profile (i.e., the

specific tool allowing

you to gather in one

space all your

achievements and

accomplishments in

Games; hereafter the

“Player Profile”) or

• contact our support

services through our

Services platform.

We use cookies and similar tracking

technologies to collect your personal

data from and store information on

your device when you use, access or

otherwise interact with our Services.

Find more information on this matter

in Section 9 below “Do we use

cookies?”

I AM A

DEVELOPER

We directly collect your

personal data when you:

• create your account

on our Websites;

• send us an email; or

• send us a game

project to analyse.

Like any other Visitor, your personal

data will be indirectly collected when

you use or access our Websites.

READY?

GO!

I AM AN

APPLICANT

We directly collect your

personal data when you apply

for a job position at Homa:

• on our Websites; or

• by any other means

(e.g., spontaneous

application send by

email or on LinkedIn)

Like any other Visitor, your personal

data will be indirectly collected when

you use or access our Websites.

WHAT PERSONAL DATA IS BEING COLLECTED?

When you access and/or use our Websites and Services, we collect certain categories of your personal

data. You know us: we don’t take much, but we give a lot! Again, pick your Homa Character to find out

more about what categories of personal data we process about you.

PICK YOUR HOMA

CHARACTER

CATEGORIES OF PERSONAL DATA COLLECTED

I AM A

VISITOR

• identification data (e.g., name);

• contact information (e.g., e-mail address, telephone number);

• technical data (e.g., IP address, type of browser used);

• any personal data contained in correspondence you send to us, if any;

and

• in case of litigation, data relating to the disputed facts and

information, documents, and exhibits collected to establish the facts

likely to be charged.

I AM A

PLAYER

• identification data (e.g., name, ID, profile pictures);

• birth date;

• contact information (e.g., e-mail address, twitter/discord ID);

• connection data (e.g., login, password);

• technical data (e.g., IP address, device information as device’s mark

and model, operating system, network used, screen size);

• data relating to your use of the Services (e.g., games played, progress

and purchases in-game, achievements, ad viewed in-game, time

stamp and duration of the connection);

• geolocation at the country level;

• any personal data contained in correspondence you send to us, if any;

and

• in case of litigation, data relating to the disputed facts and

information, documents, and exhibits collected to establish the facts

likely to be charged.

I AM A

DEVELOPER

• identification data (e.g., name, pseudonym);

• contact information (e.g., e-mail address, telephone number);

• connection data (e.g., login, password);

• data relating to your professional life (e.g., position, studio name);

• data relating to your use of the services we make available to you as

part of our contractual relationship (e.g., how often you connect)

• any personal data contained in correspondence you send to us, if any;

and

• in case of litigation, data relating to the disputed facts and

information, documents, and exhibits collected to establish the facts

likely to be charged.

READY?

GO!

I AM AN

APPLICANT

• identification data (e.g., name, first name, birth date, nationality,

photography);

• contact information (e.g., e-mail address, telephone number);

• data related to your previous professional life (e.g., previous job,

duration of your last job);

• data related to your personal life (e.g., hobbies mentioned in your CV,

if any);

• any other information spontaneously communicated in your CV, or

any other information contained in any other communication relating

to your application (e.g., letters and e-mails);

• where we invite you to interview(s) following the submission/receipt

of your application: data relating to the notes taken by Homa’s

recruitment officers during the individual interviews, including the

date of the interviews, the type and duration of the contract offered

etc.;

• data relating to the outcome of applications; and

• in case of litigation, data relating to the disputed facts and

information, documents, and exhibits collected to establish the facts

likely to be charged.

If you decide to provide us with personal data of third parties, you undertake to ensure that such

persons have been duly informed of the processing of their personal data in accordance with this Policy

and, if required, have given their approval to such processing.

FOR WHAT PURPOSES, ON WHAT BASIS AND FOR HOW

LONG DO WE PROCESS YOUR PERSONAL DATA?

Because we want this Policy to be as enjoyable to read as our Games are to play, we invite you to pick

the character that suits you the most regarding your relationship with Homa (i.e., Visitor, Player,

Developer or Applicant) to find out (i) why, (ii) on what legal basis, and (iii) for how long we process

your personal data.

Before you go, let’s remind everyone some key rules:

• depending on the circumstances, we use different legal basis to process the same personal data

for different purposes and you also have specific rights depending on the legal basis applied;

• your personal data is stored only as long as necessary for the purposes for which it has been

collected and in accordance with the applicable law - this means that the retention periods we

apply may vary depending on the purpose for which we process your personal data;

• you always have the right to request access to, rectification of or deletion of your personal data

(these are detailed in Section 6 of this Policy “What are your rights?”); and

• in any case, please note that we will not process your personal data for any other purpose that is

incompatible with the purposes listed below.

GO!

READY?

I AM A VISITOR

PURPOSES OF

PROCESSING

(WHY ?)

LEGAL BASIS

CATEGORIES OF

DATA CONCERNED

RETENTION

PERIOD

To answer your

requests and

questions, and more

broadly, manage our

relationship with you

regarding your visit

to our Websites.

We have a legitimate interest

in ensuring proper

communication with you

regarding your visit to our

Websites.

• identification

data;

• contact

information; and

• any personal

data contained

correspondence

you send to us.

Your personal

data is stored up

to 12 months after

your last contact.

To improve our

Websites.

The processing is carried out

by virtue of our legitimate

interest, which consists of

optimising our tools and

solutions in order to ensure

that you enjoy a smooth

experience on our Websites

• identification

data;

• technical data;

and

• any personal

data contained

correspondence

you send to us,

if any.

Your personal

data is stored up

to 12 months,

although in most

cases your

personal data will

be aggregated

shortly after

collection into

non-personally

identifiable

statistics.

To comply with legal

and regulatory

obligations applicable

to us (e.g., to receive

and process your

request to exercise

data personal rights).

The processing is necessary

to comply with legal

obligations to which we are

subject (e.g., to comply with

legal or regulatory requests

from judicial or

administrative authorities).

• identification

data;

• contact

information; and

• any data

contained in

correspondence

you send to us,

if any.

Your data is

stored up for as

long as we are

required to do so

by law or

regulation.

To manage any

potential or actual

disputes with you or

third parties.

The processing is carried out

by virtue of our legitimate

interest in defending our

interests, including through

legal proceedings.

• Identification

data;

• data relating to

the disputed

facts and

information,

documents, and

exhibits

collected to

establish the

facts likely to be

charged; and

• any data

contained in

correspondence

you send to us;

if any.

Your data is

stored up until all

remedies have

expired.

I AM A PLAYER

PURPOSES OF

PROCESSING

(WHY ?)

LEGAL BASIS

CATEGORIES OF

DATA CONCERNED

RETENTION

PERIOD

To make the

Services work (e.g.,

to operate the

Services, to verify

and confirm

payments).

The processing is necessary

to perform our contract with

you.

• identification data;

• contact

information;

• data relating to

your use of the

Services.

Your personal

data is stored

during the usage

period of our

services and up to

3 years after your

last contact.

To manage your

Player Profile (e.g.,

to create your

Player Profile, to

allow you to follow

your progresses

through your Player

Profile).

The processing is necessary

to perform our contract with

you.

• identification data;

• birth date;

• contact

information;

• connection data;

and

• technical data.

Your personal

data is stored up

to 12 months

after the

deactivation of

your user profile.

To make the

Services suitable for

our Players (e.g., to

develop and

improve the

Services and Player

experience by

providing you with

relevant updates,

new and enhanced

Services, to provide

you with support

service on all the

Services).

We have a legitimate interest

in providing you with the

coolest experience you could

ever dream of.

• identification data;

• contact

information;

• technical data;

• data relating to

the use of the

Services;

• geolocation at the

country level.

Your personal

data is stored up

to 2 years after

your last contact

To show

personalized

advertisements

(e.g., to track the

content you access

in connection with

the Services and

your online

behaviour, to

deliver, target and

improve advertising

of our Games and

Apps and our

partner’s services).

The processing is based on

your consent.

You can withdraw your

consent by sending an email

to our DPO to the following

address:

dpo@homagames.com.

• identification data;

• contact

information;

• connection data;

• technical data;

• any personal data

contained in

correspondence

you send to us, if

any.

Your personal

data is stored up

to 2 years after

your last contact

(unless you

withdraw your

consent).

To keep the

Services safe and

fair (e.g., to analyse

and monitor use of

the Services and its

social features, to

take action against

fraudulent or

misbehaving

players)

We have a legitimate interest

to fight fraud and ensure

acceptable use of our

Services (we do not like

cheaters).

• identification

data ; and

• any data

contained in

correspondence

you send to us, if

any.

Your personal

data is stored up

to 3 years after

your last contact.

To comply with

legal and regulatory

obligations

applicable to us

(e.g., to receive and

process your

request to exercise

data personal

rights).

The processing is necessary

to comply with legal

obligations to which we are

subject (e.g., to comply with

legal or regulatory requests

from judicial or

administrative authorities).

• identification data;

• contact

information;

• any data

contained in

correspondence

you send to us, if

any.

Your data is

stored up for as

long as we are

required to do so

by law or

regulation.

To manage any

potential or actual

disputes with you

or third parties.

The processing is carried out

by virtue of our legitimate

interest in defending our

interests, including through

legal proceedings.

• identification data;

• data relating to

the disputed facts

and information,

documents, and

exhibits collected

to establish the

facts likely to be

charged; and

• any data

contained in

correspondence

you send to us; if

any.

Your data is

stored up until all

remedies have

expired.

I AM A DEVELOPER

PURPOSES OF

PROCESSING

(WHY ?)

LEGAL BASIS

CATEGORIES OF

DATA CONCERNED

RETENTION

PERIOD

To manage your

Developer

account on our

Websites (i.e.,

particularly

Homa Lab).

The processing is necessary to

perform our contract with you.

• identification

data;

• contact

information;

and

• data relating to

your

professional life.

Your personal

data is stored

up to 2 years

from the last

interaction with

our services.

To manage our

contractual

relationship with

you as well as

the services

covered (e.g., to

monitor your

Game projects

by evaluating,

selecting and

following them

through Homa

Lab).

The processing is necessary to

perform our contract with you.

For more information, please refer

to Homa Lab Terms & Conditions by

clicking on the following link:

https://www.homagames.com/terms

• identification

data;

• contact

information;

and

• data relating to

your

professional life.

Your personal

data is stored

for the duration

of the

contractual

relationship.

To carry out

commercial

prospecting and

promotion of our

The processing is based on your

consent.

• identification

data;

Your data is

stored up to 3

years after the

end of our

Services (e.g.,

send you special

offers,

promotional and

commercial

content, adapt

our commercial

offers and the

content of the

Newsletter to

your

preferences) or

inviting you to

our events

(Homa Club, jam

sessions, etc).

You can unsubscribe to our

newsletter at any time by clicking

on the unsubscribe link available in

each of our communication or by

contacting our DPO to the following

address: dpo@homagames.com

• contact

information;

and

• data relating to

your

professional life.

contractual

relationship.

If you are a

prospect, with

your

authorization,

your personal

data is stored

up to 3 years

after your last

contact.

To comply with

legal and

regulatory

obligations

applicable to us

(e.g., to receive

and process

your request to

exercise data

personal rights).

The processing is necessary to

comply with legal obligations to

which we are subject (e.g., to

comply with legal or regulatory

requests from judicial or

administrative authorities).

• identification

data;

• contact

information;

• any data

contained in

correspondence

you send to us,

if any.

Your data is

stored up for as

long as we are

required to do

so by law or

regulation.

To manage any

potential or

actual disputes

with you or third

parties.

The processing is carried out by

virtue of our legitimate interest in

defending our interests, including

through legal proceedings.

• identification

data;

• data relating to

the disputed

facts and

information,

documents, and

exhibits

collected to

establish the

facts likely to be

charged; and

• any data

contained in

correspondence

you send to us;

if any.

Your data is

stored up to 5

years after the

end of our

contractual

relationship.

I AM AN APPLICANT

PURPOSES OF

PROCESSING

(WHY ?)

LEGAL BASIS

CATEGORIES OF

DATA CONCERNED

RETENTION PERIOD

To process your

application (CV and

cover letter) and

manage interviews.

The processing is

necessary for the

execution of pre-

contractual

measures taken at

your request.

• identification data;

• contact

information; and

• data relating to

your professional

life.

• any personal data

contained in

correspondence

Your personal data is

stored up to 3 months

after the completion of the

admission procedure – so

we can get in touch with

unsuccessful applicants to

explain our refusal.

If you consent, your data

is stored up to 2 years

you send to us; if

any.

from the last contact with

you.

To comply with

legal and regulatory

obligations

applicable to us

(e.g., to receive and

process your

request to exercise

data personal

rights).

The processing is

necessary to

comply with legal

obligations to

which we are

subject (e.g., to

comply with legal

or regulatory

requests from

judicial or

administrative

authorities).

• identification data;

• contact

information;

• any data contained

in correspondence

you send to us, if

any.

Your data is stored up for

as long as we are required

to do so by law or

regulation.

To manage any

potential or actual

disputes with you or

third parties.

The processing is

carried out by

virtue of our

legitimate interest

in defending our

interests, including

through legal

proceedings.

• identification data;

• data relating to the

disputed facts and

information,

documents, and

exhibits collected

to establish the

facts likely to be

charged; and

• any data contained

in correspondence

you send to us; if

any.

Your data is stored up

until all remedies have

expired.

WITH WHOM DOES HOMA SHARE YOUR PERSONAL

DATA?

In the context of processing your personal data in accordance with this Policy, we communicate your

personal data to the following Third Parties:

our service providers, external suppliers, payment service providers, agents and contractors, to

the extent that they assist us in carrying out the purposes set out in this Policy;

partners which may collect your personal data on our Services and Websites via cookies and similar

tracking technologies, subject to your prior and express consent. For more information, you can

check the Section 9 below “Do we use cookies?”; and

competent courts, public authorities, government agencies and law enforcement agencies (e.g., in

cases where we are required to comply with legal or regulatory requests).

For further information on the processing of personal data communicated to Third Parties, you can

check the relevant Third Parties privacy policy, available on each Third Parties dedicated area. Please

note that Third Parties are solely responsible for the processing of your personal data carried out by

such Third Parties.

WHAT ARE YOUR RIGHTS?

In accordance with the applicable personal data protection regulation, including the General Data

Protection Regulation, you have the following rights: right to access, request rectification, request

deletion, object, limit the processing, request the portability of your personal data and the right to

10"

provide instructions on the use of your personal data after your death. Do not worry, these spells are

described below!

When the processing of your personal data is based on your consent, you may withdraw it at any time.

RIGHT OF ACCESS

You may request access to your personal data at any time. If you exercise

your right of access, we will provide you with a copy of your personal data in

our possession as well as all information relating to its processing.

RIGHT OF RECTIFICATION

You have the right to ask us to rectify or complete any personal data in our

possession that you consider to be inaccurate or incomplete.

RIGHT TO ERASURE

You can ask us to delete your personal data, for example if it is no longer

necessary for the processing we carry out.

We will make our best efforts to comply with your request. Please note,

however, that we may have to retain some or all of your personal data if we

are required to do so by applicable law or if the personal data is necessary for

the establishment, exercise, or defence of our rights.

RIGHT TO OBJECT

You may object at any time, on grounds relating to your particular situation,

if we use your personal data. We will then stop processing your personal data

unless there are overriding legitimate grounds for continuing to process your

personal data (for example, if your personal data is necessary for the

establishment, exercise or defence of our rights or the rights of third parties

in court proceedings). If we are unable to comply with your request to object,

we will inform you of the reasons for our refusal.

You can also object at any time to our processing of your personal data for

marketing purposes.

RIGHT TO RESTRICT PROCESSING

You may also request that we restrict the processing of your personal data on

grounds relating to your particular situation. For example, if you dispute the

accuracy of your personal data or object to the processing of your personal

data, you may also request that we do not process your personal data for the

time necessary to verify and investigate your claims.

In this case, we will temporarily refrain from processing your personal data

until necessary verifications have been made or until we comply with your

requests.

RIGHT TO DATA PORTABILITY

You may request portability of the personal data you have provided us with.

At your request, we will provide you with your personal data in a readable and

structured format so that you can easily re-use it.

The portability of your personal data applies only to personal data that you

have provided to us or that result from your activity on our Platform, under

the condition that the disclosure of your personal data does not infringe the

rights of third parties. If we are unable to comply with your request, we will

inform you of the reasons for our refusal.

RIGHT TO WITHDRAW CONSENT

You have the right to withdraw consent at any time for personal data

processing based on consent. Withdrawing your consent prevents us from

11"

processing your personal data but does not affect the lawfulness of the

processing carried out before the withdrawal.

RIGHT TO PROVIDE INSTRUCTIONS ON THE RETENTION AND

COMMUNICATION OF YOUR PERSONAL DATA AFTER YOUR DEATH

You can provide us with instructions on how to use your personal data after

your death. For example, you can request that we retain, delete, or transfer

your personal data to a third party that you have designated.

HOW CAN YOU EXERCISE YOUR RIGHTS?

If you wish to exercise your rights, you may contact our DPO to the following address:

dpo@homagames.com

To be able to process your request efficiently, we may ask you additional information to confirm your

identity and/or to ease retrieval of personal data concerned by your request.

Please note that some of your rights are subject to specific conditions laid down in the applicable

personal data protection regulation. Therefore, if your particular situation does not meet these

conditions, we will unfortunately not be able to respond to your request. In this case, we will inform

you of the reasons for our refusal.

In any case, please note that you can lodge a complaint with the French Data Protection Authority

(Commission Nationale de l'Informatique et des Libertés) (“CNIL”).

DO WE TRANSFER YOUR PERSONAL DATA OUTSIDE THE

EUROPEAN ECONOMIC AREA?

YES

For the purpose of processing your personal data as described in this Policy, we have to send your

personal data very, very, very far away … Well, outside the European Economic Area ("EEA”).

WHERE EXACTLY?

To another world: United States of America.

In these cases, we implement appropriate transfer mechanism and safeguards to ensure that the

personal data transferred benefit from the same level of protection as within the EEA.

In practice, the transfer is at least based on one of the following mechanisms:

the existence of an adequacy decision issued by the European Commission for the country to

which your personal data is transferred; or, failing that

the conclusion of standard contractual clauses as adopted by the European Commission; or,

failing that the existence of an exemption linked to one of the specific situations exhaustively

provided for by the General Data Protection Regulation n°2016/679 ("GDPR"). For example,

where you have explicitly given your consent to the proposed transfer after having been

informed of the absence of safeguards, where the transfer is necessary for the performance

of a contract between you and us, where the transfer is necessary for the conclusion or

performance of a contract concluded, in your interest, between us and a third party, or where

the transfer is necessary for the establishment, exercise or defence of our legal claims, etc.

12"

You may request a copy of these documents by contacting our DPO to the following address:

dpo@homagames.com.

DO WE USE COOKIES?

YOU USE CAKE?

Not really… Here’s the thing: cookies and similar tracers, such as “Flash” cookies, “local storage”, etc.,

(hereinafter “cookies”) are files that are placed on a user’s terminal when the user uses an application

or visits a website. They are used to store information on the user’s terminal so that it can be accessed

later.

YES

We use cookies on our Websites and Services. Our Websites and Services also contains Third Parties

tracking, data collection and analytics tools.

Pursuant to the applicable regulation on cookies and other tracking technologies, please note that we

will ensure that we have obtained, where necessary, your prior consent before placing them on your

equipment.

The privacy policies of Third Parties may include additional terms and disclosures regarding their data

collection and use practices and tracking technologies we recommend you check. You can check out the

list of Third Parties that set cookies and tracking tools on our Services on Usercentrics.

WHAT COOKIES DO WE USE?

Where you pressed “YES!”, we use the following cookies and other tracking tools on our Websites and

Services:

• if you are using an Apple device, the Identifier for Vendor (IDFV) and/or the Identifier for

Advertisement (IDFA) of your device;

• if you are using an Android device, the Google Advertising Identity (“AAID”);

WHY DO WE USE COOKIES?

Where you pressed “YES!”, we and/or Third Parties use cookies to:

• ensure our Websites and Services function properly (we know what players hate the most: lags!)

• allow publishers to offer advertising inventory in their apps, and advertisers to bid on and display

ads in that inventory,

• improve, customize, and personalize our Services to your habits and preferences (e.g., if a Game

is too hard or so easy that you just stop playing, we want to know it in order to adapt our Game

to your level), and provide you with targeted advertising and recommendations on games we think

you would like.

WHAT PERSONAL DATA DO WE COLLECT VIA COOKIES?

Where you pressed “YES!”, we and/or Third Parties, collect the following categories of personal data:

• your App’s access and session duration;

• how you interact with advertisement;

• device maker, model and operating system;

• device properties related to screen size and orientation;

• audio volume and battery;

• carrier;

• operating system;

13"

Last update : May 17th, 2023

• name and properties of mobile application through which a Player interacts with the Services;

• country, time zone and local settings (country and preferred language);

• network connection type and speed;

• IP address; and

• Internet browser user-agent used to access the Services.

HOW CAN YOU WITHDRAW YOUR CONSENT?

You can withdraw your consent to the use of Third Parties cookies and other tracking tools through the

settings of our Apps and Games or the cookies management solution present on our Websites or by

contacting our DPO (dpo@homagames.com).

WHAT ABOUT CHILDREN PRIVACY?

Minors below 16 years old cannot create a Player Profile.

Homa does not intentionally collect personal data from minors aged under 16. If we realize we have

collected personal data regarding a minor within the meaning of the applicable data protection

regulation, we will immediately delete it.

WHEN AND HOW WILL YOU BE INFORMED IF THIS

POLICY CHANGES?

We periodically review this Policy to ensure it is compliant and up to date with applicable data protection

regulation.

You will be notified in case of substantial changes to the Policy (for example, if the modifications impact

the categories of personal data processed or the purposes of processing), and we will send you a

hyperlink to the updated Privacy Policy within 30 days before publication. This information will be

provided to you by email or will be made available via a pop-up window displayed when visiting our

Websites. This will give you the opportunity to review the updated Policy before you decide whether to

continue using our Services.

Good Game Well Played!