General personal data protection policy

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

PulluP Entertainment (hereinafter “We” or “our” or “PulluP 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 Personal Data Protection Policy (hereinafter the “Policy”) transparent information relating to the protection of your Data collected and processed by PulluP Entertainment through its Website.

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

by email at the following email address: personaldata@focusent.com; or
by post: PulluP Entertainment, Parc du Pont de Flandre, Bâtiment 28 “Le Beauvaisis”, 11 rue de Cambrai, 75019 PARIS.

Summary

Definition
Description of Data processing
Recipients of the Data collected
Transfer of Data outside the EEA
How to exercise your rights
Data Security
Minors
Hypertext links to other websites
Policy Change and Update

1. DEFINITIONS

Shareholder: refers to any natural person or permanent representative of a legal entity holding a stake in the capital of PulluP Entertainment;

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

Partners: refers to PulluP Entertainment’s business and commercial partners, including external development studios, as well as any PulluP Entertainment supplier or subcontractor.

Data Controller or PulluP Entertainment: refers to the company PULLUP ENTERTAINMENT, a société anonyme [public limited company] registered under No. 399 856 277 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: refers to the websites published and operated by PulluP Entertainment, accessible via the address https://pullupent.com/fr/.

Visitors: refers to any adult natural person who accesses the Website.

2. DESCRIPTION OF DATA PROCESSING

PulluP Entertainment collects your Data directly in the following cases:

Deposit of cookies and other tracers (as described in our policies on cookies accessible on our Websites);
When a representative of a Partner (employee or corporate officer) comes into contact with a PulluP Entertainment representative (employee or corporate officer);
When a Shareholder contacts a representative of PulluP Entertainment (employee or corporate officer).

PulluP Entertainment collects your Data directly in the following cases:

The categories of Data we collect and the purposes for which they are collected are described in the table below.

Please note that this Policy supplements any information that has already been given to Shareholders in connection with the acquisition or resale of securities.

In addition, 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.

PROCESSING	DATA SUBJECTS	DATA CATEGORIES	PURPOSE(S) OF THE PROCESSING	LEGAL BASIS OF THE PROCESSING	RETENTION PERIODS
Cookies and other tracers	Visitors to the Website	Browsing information collected and processed during your visit to our Website and your options regarding the settings of these cookies. For more information on the Data collected via cookies, please refer to our Cookies Policy.	Ensure the proper functioning of the Website	Legitimate interest (only functional cookies)	See our Cookies Policy.
Business relationship management	Representatives of PulluP Entertainment Partners (Employees or corporate officers)	Contact data (surname, first name) Contact details (telephone number, email address, company postal address) Professional data (position occupied, past or current positions, qualifications and/or professional experience)	Communication with representatives of PulluP Entertainment Partners in any economic transaction	Pre-contractual or contractual measure	Data relating to any contractual relationship is retained for a period of 5 years from the end of the contractual relationship The Data concerned is then deleted or stored in an intermediate database, particularly in the event of litigation.
Sharing information related to PulluP Entertainment news	Shareholders	Identification data (surname, first name, nationality) Contact details (telephone number, email address, postal address) The registry number or, failing that, the unique identifier such as the legal entity identifier (LEI code) The number of shares held Restrictions that may apply to the securities	Communication with shareholders to facilitate the exercise of shareholder rights and shareholder engagement in the company Keeping records (succession, general meetings) Payment of dividends	Legal obligation	Data relating to any shareholder relationship will be kept on an active basis for a period of 10 years from their collection. The Data concerned is then deleted or stored in an intermediate database, particularly in the event of litigation.
Management of disputes with Partners	Representatives of PulluP Entertainment Partners (Employees or corporate officers)	Contact data (surname, first name) Contact details (telephone number, email address, company postal address) Professional data (position occupied, past or current positions, qualifications and/or professional experience)	Communication with representatives of PulluP Entertainment Partners or shareholders in connection with any disputes with the latter	Legitimate interest	Retention of Data in intermediate database for the duration of the procedure and up to 10 years from the enforcement of the final decision.
Management of disputes with Partners	Shareholders	Identification data (surname, first name, nationality) Contact details (telephone number, email address, postal address) The registry number or, failing that, the unique identifier such as the legal entity identifier (LEI code) The number of shares held Restrictions that may apply to the securities		Legitimate interest
Management of requests to exercise rights	Anyone sending a request	Identification data (surname, first name) Contact details (email and/or postal address) Rights exercised and method of communication chosen	Manage and monitor requests to exercise rights received and ensure the effective processing thereof	Legal obligation	the Data will be kept for the period necessary to process the request, increased by the legal limitation periods: 6 years for the right of opposition, 5 years for other rights.

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.

When PulluP Entertainment retains your Data for longer periods, when justified, these Data are stored in intermediate archiving, i.e. separately from the active database and with restricted access.

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

3. RECIPIENTS OF THE COLLECTED DATA

Communication of Data to our service providers and suppliers

Certain Data we collect may be communicated and/or shared with 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 provide the requested 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.

4. TRANSFER OF DATA OUTSIDE THE EEA

PulluP Entertainment may transfer some of your Data outside the European Economic Area (EEA), for technical and operational purposes, to enable us 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.

5. HOW TO EXERCISE YOUR RIGHTS

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 PulluP 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.
Right to the portability of your Data: this right applies when the processing is 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: PulluP Entertainment, 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), PulluP 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 Publishing as data controller, in connection with those of PulluP Entertainment as data processor.

6. DATA SECURITY

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 PulluP 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

PulluP 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. POLICY 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.