GUILLEMOT INC.’S PRIVACY POLICY

Effective Date: 11/19/2025

Last updated on: October 1, 2025

1.                  OVERVIEW

This privacy policy (“Policy”) applies to Guillemot Inc. (“Guillemot,” “we,” or “us”). We strive to deliver quality products and services and value our customers’ business and loyalty. We recognize that privacy is an important issue. We have developed this Policy to explain our practices regarding the personal information we collect from you or about you (eg. when you create your account, purchase products or license, through written or verbal communications with us, when you use this website (“Site”) or mobile applications). While this Policy broadly describes the practices we have adopted across Guillemot within the United States and Canada, local laws vary, and some jurisdictions may place restrictions on our collection, use, or disclosure of personal information. Our actual practices in such jurisdictions may be more limited than those described in the core of this Policy to comply with local requirements. You may find specific information below the core of this Policy (in its appendices).

By accessing or using our websites, any application software (“apps”), or submitting information to us, or otherwise agreeing to this Policy, e.g. in the context of establishing an account with us, you understand and consent to our collection and use of your personal information as described herein.

Please note that this Policy does not apply to our processing of personal information on behalf of and subject to the instructions of third parties.

2.                  PERSONAL INFORMATION WE COLLECT

We may collect personal information at every consumer interaction and in conducting every aspect of our business.  We collect personal information in certain common cases, including:

Purchase: In connection with your purchases of products or licenses sold by third parties through our brand websites, we collect personal information.  The information we collect in these cases may include first name, last name; telephone number; email address; street address(es) (billing street address including number, street, city, county, state, Province, or territory, zip code, country; delivery (or shipping) street address, number, street, city, county, state, Province, or territory, zip code, country); company; preferred language; precontractual or contractual representations (e.g. confirmation that you are of legal age and legally able to make a contract, agreement, acknowledgement of license agreement, acknowledgement of information, etc.); timestamps; Guillemot or related products or licenses owned, license information (including, but not limited to, version, duration, and expiration date); account password; shopping cart content; coupon code; order or pre-order information; Details regarding products purchased or subscriptions (licenses) purchased; customer comments; wish list; reviews of products, licenses, or services; nickname; date of purchase; invoice information; payment method (eg. credit card, PayPal, Klarna, Google Pay); payment information; for credit card method, credit card issuer, card number (credit card number is mostly redacted in our records), expiration date and security code. The personal information described in this paragraph is the “Purchase Data”.  Purchase Data is obtained from you or is generated by the reseller and merchant in fulfilling your order or pre-order.

Experience: If you decide to share your experience through our websites or apps, or on social media, we collect personal information in connection with your purchase or in connection with our products, licenses, or services.  The information we collect in these cases may include first name, last name, nickname; telephone number; e-mail address; number, street, city, county, state, Province, or territory, zip code, country; rating; review, summary; language; Guillemot or related products owned, tested or otherwise used; date.  The personal information described in this paragraph is the “Experience Data”.  Experience Data is obtained from you.

Business-to-Business: In connection with the exercise of your job or function for a third party (eg. your purchase of goods or services for your business, our purchase of your goods or services for our business), we collect information which may include company information; first name, last name; title, function; signature, initials; work telephone number; work email address; shipping or delivery address, including, number, street, city, county, state, Province, or territory, zip code, country; destination address, including, number, street, city, county, state, Province, or territory, zip code, country; billing address, including, number, street, city, county, state, Province, or territory, zip code, country; preferred language; order information; goods purchased or services subscribed; date of purchase or subscription; marketing information; dates of events or marketing operations; involved agents, partners, or service providers; invoice information; bank details; payment information; forecasts; needs; requirements; negotiation terms; agreements; customs information; issues, remedial action taken; preferred communication channel; chat, email, fax, or telephone communications, communication recordings, summaries and/or transcripts; meeting schedules; meeting reports; proof of delivery, proof of expenses; certificates. The information described in this paragraph is the “Business-to-Business Data”.  Business-to-Business Data is obtained directly from you or is generated by us in fulfilling your order or another contract between Guillemot and said third party. Business-to-Business Data are the subject of various levels of privacy protection, depending on the applicable law.

Accounting: In connection with the exercise of your job or function for a third party or for Guillemot, we collect information which may include company registration certificate; company’s officers, legal representatives; shareholding structure; number of employees; first name, last name, title, function; telephone number; email address; shipping address, including, number, street, city, county, state, Province, or territory, zip code, country; billing address, including, number, street, city, county, state, Province, or territory, zip code, country; preferred language; order or pre-order information; goods or services purchased; date of purchase; invoice information; Bank details (for business); payment information; debt recovery information. The information described in this paragraph is the “Accounting Data”.  Accounting Data is obtained directly from you or is obtained from third parties (banks, company registrars, payment insurers, debt recovery agencies, commercial data providers, data analytics and insights service providers). Accounting Data are the subject of various levels of privacy protection, depending on the applicable law.

After-Sale Service:  In connection with providing you with after-sales or support service, we may collect personal information including, first name, last name, gender, telephone number, email address; shipping address, including, number, street, city, county, state, Province, or territory, country, zip code; proof of delivery; billing address, including, number, street, city, county, state, Province, or territory, zip code, country; preferred language; birthday; Guillemot products owned, Guillemot product brand; serial number of Guillemot products owned; technical context, hardware used, software used, network used, accessories used; account name, account password; support category, (request) title (e.g. “Is hardware H compatible with software S?”); description; any documents provided; order or pre-order information; products, licenses, and services purchased; seller name; customer comments; date of purchase; invoice and invoice information; service issue; remedial action taken; chat, email, or telephone communications, communication recordings, summaries and/or transcripts; preferred communication channel; support ticket source. We generate a support ticket code, a unique customer code (an internal number we use to identify the same requester regardless of communication channel (email, telephone, etc.)), and we determine a priority level, a support ticket status, a number of support tickets opened with us, a date of first contact, a date of last interaction, a number of contacts, and levels of satisfaction (e.g. in the form of a star rating), a list of incidents (an incident means a request or complaint) raised by a requester (you), the number of days since the last interaction, the date of the last incident and the number of incidents.  We may collect one or more photos or videos explaining your problem. The personal information described in this paragraph is “After-Sale Service Data”.  After-Sale Service Data is collected from you or is generated by us in responding to your service request.

Newsletter: If you subscribe to our newsletters we may collect personal information including first name, last name; email address; newsletter subscribed, subscription date, and preferred language. The personal information described in this paragraph is “Newsletter Data”.  Newsletter Data is collected directly from you.

Social Media: If you choose to post review(s) on social media, and/or if you choose to participate in Guillemot-sponsored social media activities or offerings, we may collect your affiliate link (only for Guillemot-sponsored social media activities or offerings) and certain information from your social media account consistent with your settings within the social media service, such as pseudonym(s), location, check-ins, activities, interests, texts of reviews, photos, videos, status updates, and friends list. We may also allow you to enter into contests to provide photos or videos, such as of products you purchased, which you may share with your connections on social media for votes, shared offers or other promotions. The personal information described in this paragraph is the “Social Data”.  Social Data is collected directly from you or through your social media account.

Contests and Sweepstakes: We may run contests or sweepstakes in which you may choose to participate. The personal information we collect may include first name, last name, email address, social networking pages, participation date and timestamp, telephone number, address, date of birth, skill-testing question response and/or other individual responses as indicated at the time of collection. Prize winners may be required to provide a social security number for tax reporting purposes.  To obtain reimbursement of internet connection fees -if applicable- and/or other costs -if applicable- regarding a contest or sweepstake in question, additional personal information may be collected such as a letter of request for reimbursement, a bank statement, photocopy of an official form of identification, a photocopy of proof of address, and a detailed telephone bill indicating the time and date of participation in the contest or sweepstake in question. The personal information described in this paragraph is the “Contest and Sweepstakes Data”.  The Contest and Sweepstakes Data is collected directly from you.

Customer Surveys: We may collect personal information at various events through surveys in which you may choose to participate. The information we collect may include age; date collected; purchase history, habits, needs, and preferences; email address; first name; last name; and other individual survey responses as indicated at the time of collection. The personal information described in this paragraph is the “Survey Data”.  Survey Data is collected directly from you.

Automatically Collected Personal Information: By its nature, our websites and apps also automatically collect some personal information about you. In order for you to view or interact with our website or apps, we receive individual identifiers like your IP address, an affiliate link (if you used an affiliate link to arrive at the website), your feedback or behavior regarding a CAPTCHA, a user ID (a universal non-personally identifiable unique identifier to distinguish new users from existing and former users), apps identifiers (app ID, app version), operating system (name and version), CPU architecture (number of bits, e.g. 32 or 64), display resolution, language, country, and some network information like your internet service provider (ISP), the type of device you are using (computer, telephone, etc.), the operating system (OS) you are using, the time at which you began browsing, the number of page(s) viewed, the specific page being viewed, the date and time of pages visited, the browser language and web browser you are using. We may collect this personal information even if you are not logged in.  We collect some personal information automatically using cookies or other tracking technologies as described below in Section 7. The personal information automatically collected may be collected by or on behalf of third parties who may provide us inferences or aggregate reporting based on analysis of such personal information. The personal information described in this paragraph is the “Use Data”.

Team Data: We collect information in the context of your role as a team member (i.e. your role as an applicant to, an employee of, internship of, director of, or officer of, our business) i.e. for human resources management. The information we collect in these cases may include first name, last name, middle name, gender; copy of ID card, Canadian or foreign passport, driver’s license (or learner's permit or probationary licence issued by Québec, another Canadian province or territory or a US state); organization (employer); department; function or title, dates and conditions of hiring or recruitment; employment contract; signature, initials; type of contract; duration of the contract, i.e. definite/indefinite; duration of the working time and its distribution (work schedule); ID number (internal number); social security number; address; date and city of birth, citizenship and country of origin; bank details; tax filing status; email address; telephone number; marital status, family member names; educational background, diplomas, certificates, studies, training periods completed, language(s), type of driver's license held - for employees whose job involves using a company vehicle -; Curriculum Vitae; criminal background -if suitable- and employment history, references or recommendations; wishes in terms of employment; medical provider information; dependent’s first names, last names, dates of birth, genders, addresses, and medical insurance providers; workplace; managers; individual evaluation reports; date, object and reason for changes made to the employee's professional situation; addendum to the individual employment contract; period, reasons for suspension and date on which the suspension of the individual employment contract ends; date and legal basis for the termination of the individual employment contract; hierarchical information (if N is you, your N+2, N+1, N-1, N-2, ...); team information (employees with whom the team member is working); medical examination dates, medical certificates; contact details of the occupational physician; date of the accident or the first medical finding of the occupational disease; date of the last working day, date of resumption, reason for the 'stoppage (work accident or occupational disease), work not resumed to date; contact details of a close person in case of emergency -if you give us such data-; basic gross monthly salary, allowances, bonuses and other allowances; information and evidence provided by the team member for reimbursement of expenses; disciplinary sanctions; Court decision regarding payment; professional needs and individual allocations (eg. mobile computer, telephone, vehicle, payment card, ...), requests, nature of the allocation, allocation, maintenance and withdrawal dates, budget allocations; information regarding the IT (Information Technology) tools held (ID, designation, serial number, comment); communications (emails, letters, transcript of phone calls, ... ); professional phone number; professional email address, password, PIN code, fingerprint, facial recognition data, and username through which the team member connects to the IT network; computer directories used to define access authorizations to applications and networks; connection data; information regarding the attendance of a team member to an event organized by or for us; employee’s requests for vacation (paid leave, unpaid leave); family situation (eg. marriage, dependents, parent of children); particular constraints giving rise to the right to special leave or to a credit for hours; information for the procedure for electing employee representatives; passport references -for employees whose job involves travelling abroad; off or present or homeworking status; professional agendas (dates, places and times of professional events or meetings, purpose, people present); stock options, global quantity awarded; identification and business contact data; endpoint and endpoint usage data (e.g., active directory user ID, installed applications); network and network usage data (e.g., IP address, URLs); log data; team information; mailing lists membership; photo; video -for employees whose job involves using video conferencing tools-; address book, individual accounts; availability status -for employees whose job involves using team collaboration tools-. We use this information for purposes of evaluating qualifications related to your job application or your job duties; for purposes of security; for providing compensation, benefits, and services in the context of the employment relationship, internship, or management mandate, for fulfillment of accounting, tax, labor, and social insurance obligations; for management of actual or potential litigation or pre-litigation matters; for management of stock options, for provision of Team members of Guillemot Companies with IT tools, and for logistics. The information described in this paragraph is the “Team Data”.  The Team Data about you that regards the exercise of your job for us is information that is the subject of various levels of privacy protection, depending on the applicable law. 

User Access: If you choose to purchase one or more subscriptions (licenses), we may collect further information to be merged with certain information from your Purchase Data and Use Data. The information we collect in these cases may include first name, last name; e-mail address; preferred language; licenses owned, their version and their duration; expiration date; account password; last connection date, number of connections; date of update; timestamps; and we may further collect the names and characteristics of the products (or devices) associated with the licenses, the MAC address of each product (or device) associated with a license, the total number of products (or devices) associated with the license. For each product (or device) associated with the license, an identifier (token) may be generated. The personal information described in this paragraph is the “User Access Data”. User Access Data is collected directly from you or generated automatically.

Legal issues (actual and potential litigation and pre-litigation, legal evidence, requests or orders from authorities or courts, …): In connection with our duty to complete a transaction for which the personal information was collected, our right to exercise or defend legal claims, our compliance with applicable laws and regulations (eg. to enable us to prove our compliance to authorities or courts), and our cooperation with law enforcement agencies, we collect all the above categories of information (Purchase Data, Experience Data, Business-to-Business Data, Accounting Data, After-Sale Service Data, Newsletter Data, Social Data, Contest and Sweepstakes Data, Survey Data, Use Data, Team Data, User Access Data). The information described in this paragraph is the “Legal Data”.

In addition to the information we collect from you directly, we may also infer information about you based on the information you provide to us or from other information we collect.

3.                  PERSONAL INFORMATION FROM OTHER SOURCES

We may collect personal information about you from a number of sources in addition to those means of collection indicated above, including offline or through sources unrelated to your interaction with our websites or apps. For example, we may collect personal information from publicly accessible sources (e.g., phone number records, property records, or company registrars); from Business-to-Business relationship (your colleagues, manager, or employer may provide us with Business-to-Business Data), directly from a third party (e.g., credit reporting agencies, customer due diligence providers, or telephone service providers, commercial data providers, data analytics and insights service providers, payment services providers, payment insurers, debt recovery agencies, employment agencies or platforms, schools, colleges, universities or other education organisations, referees, occupational health and other health providers, staff benefit providers, public entities, IT service providers); or from a third party with your consent (e.g., your bank, your legal representative, or your doctor (your doctor’s certificates). We may merge or co-mingle that personal information with the personal information we maintain about you and other data collected on or through our website.

4.                  PURPOSES FOR WHICH WE COLLECT PERSONAL INFORMATION

In addition to the reasons set forth above, we collect your personal information for the following reasons:

·         Auditing related to a current interaction with the customer and concurrent transactions, including, but not limited to, counting ad impressions to unique visitors, verifying positioning and quality of ad impressions, and auditing compliance with this specification and other standards;

·         Detecting security incidents, protecting against malicious, deceptive, fraudulent, or illegal activity, and prosecuting those responsible for that activity;

·         Debugging to identify and repair errors that impair existing intended functionality;

·         Short-term, transient use; provided that, the personal information is not disclosed to a third party and is not used to build a profile about a customer or otherwise alter an individual customer’s experience outside the current interaction, including, but not limited to, the contextual customization of ads shown as part of the same interaction;

·         Performing services on our behalf, including maintaining or servicing accounts, providing customer service, processing or fulfilling orders, pre-orders, and transactions, verifying customer information, processing payments, providing financing, providing advertising or marketing services, providing analytic services, or providing similar services on behalf of the business;

·         Undertaking internal research for technological development and demonstration;

·         Undertaking activities to verify or maintain the quality or safety of a service or device that is owned, manufactured, manufactured for, or controlled by the business, and to improve, upgrade, or enhance the service or device that is owned, manufactured, manufactured for, or controlled by the business;

·         Team members’ safety and health;

·         Safety of persons and property of employees and Guillemot Companies;

·         Team members’ internal relationship;

·         Management of actual or potential litigation or pre-litigation matters, including exercising or defending legal claims, and responding to requests or orders from authorities (or courts); and

·         Reporting to public entities as required by law.

5.                  LIMITED USE

We will only use your personal information as is reasonably necessary and proportionate to achieve the purpose for which the personal information was collected or processed or for another purpose that is compatible with the context in which the personal information was collected.

6.                  HOW WE SHARE PERSONAL INFORMATION

In order the designer, manufacturer, or licensor of the products to provide the best products and services, we share your personal information among our affiliates, service providers, and other third parties as described below.

6.1              Guillemot Companies

We may share some or all of your personal information with our parent company and entities under its control (“Guillemot Companies”) for the purposes described in Sections 2 and 4 above. Further details may be provided in an Appendix which is relevant to your case.

6.2              Fulfillment Providers. We share personal information with companies that fulfills your requests and orders or pre-orders for products, licenses, or services (“Fulfillment Providers”) including, but not limited to, the reseller and merchants,  shipping companies, warehousing and handling service providers (for order or pre-order preparation and packaging), customs clearance service providers, IT service providers, legal services providers, product return handling service providers, repairs service providers.

6.3              Advertising Networks. We share personal information with third parties that help the relevant reseller and merchant market to you and may use such information to market to others (“Advertising Networks”) as further described in Section 7 of this Policy.

6.4              Service Providers

We may, from time to time, use business partners, suppliers, and sub-contractors (“Service Providers”) to assist us with the provision of services to you or for services to us in connection with the performance of a contract with you (for example, without limitation, website hosting, consent management services, social media data collection providers, emailing services, form building, surveys organization, contests and sweepstake organization, loyalty management, customer reviews management, telecommunication service providers, phone calls management, chatbot management, IT services (including without limitation IT security services, forensic investigations services), artificial intelligence powering services, invoice processing and approval, payment service providers, payment insurer, app design, maintenance services, database management, web analytics, app analytics, billing, payment processing and reporting, debt recovery agencies, cashing processing and reporting, fraud protection, credit risk reduction, marketing, advertising, customer relationship management, improvement of services, logistics, packing, repair services, technical review and/or analysis services, transport services, private medical service, vocational training, meal voucher/card supply, management of stock option plans, contract signature, archives storage, cloud, collaborative communication, collaborative project management, Human Resources (HR) service providers, contract management service providers, counsels and lawyers). These Service Providers have access to your personal information only to perform the respective tasks assigned to them on our behalf, and are obligated not to disclose or use it for any other purpose.

6.5              Third Parties

In addition to third parties in the foregoing categories, we may share personal information with the following categories of third parties: Data Analytics Providers as defined in Section7, public entities (eg. law enforcement agencies, courts, customs, financial administration, health insurance administration, labour administration, social insurance administration, etc.), auditors, internet service providers, operating systems and platforms, social networks.  For the purposes of this Policy, “third party” or “third parties” means third party as defined by the California Consumer Privacy Act, and includes parties that may sell, retain, use, or disclose personal information for certain purposes beyond the limited scope of our contract or direct business relationship with such entities.

6.6              Other team members

We may disclose pieces of your Team Data to other team members of Guillemot Companies for team’s internal relationship as reasonably determined by us and as permitted by any applicable law or regulation.

6.7              Other Business-to-Business relationship

We may disclose pieces of your Team Data or Business-to-Business Data (personal information which is business contact information such as first name, last name, title, function, email address, business phone number, business fax number, and similar business information in connection with your work for us) to Business-to-Business relationship and company registrars as reasonably determined by us and as permitted by any applicable law or regulation.

6.8              Public

We may disclose pieces of your Experience Data to the public thereby following your wish. If you are amongst the winner(s), we may disclose pieces of Contest and Sweepstakes Data to the public (e.g. publish them on the social network on which the contest or sweepstake in question is organized).

6.9              Compliance with Laws

We cooperate with government and law enforcement officials and private parties to enforce and comply with the law. We may disclose your personal information to government or law enforcement officials or private parties in response to lawful requests when we believe disclosure or sharing is necessary to comply with any legal obligation, enforce or apply our Terms of Use, the terms and conditions, respond to claims and legal process, protect the safety of the public or any person, or prevent or stop any illegal, unethical or legally actionable activity (including for the purposes of fraud protection).

6.10          Sale or Transfer of Business or Assets

We may share some or all of your personal information in connection with or during negotiation of any merger, financing, acquisition or dissolution transaction, or proceeding involving sale, transfer, divestiture, or disclosure of all or a portion of our business or assets. In the event of an insolvency, bankruptcy, or receivership, personal information may also be transferred as a business asset. If another company or individual acquires our business, or assets, that company or individual will possess the personal information collected by us and will assume the rights and obligations regarding your personal information as described in this Policy.

6.11          Other Legitimate Business Purposes

We may also disclose your personal information when it may be necessary for other legitimate purposes as reasonably determined by us and as permitted by any applicable law or regulation.

7.                  COOKIES AND OTHER TRACKING TECHNOLOGIES

Third parties, including Google, Facebook, Microsoft, Amazon, Reddit, Tiktok, Twitch, and X Corp. (ex-Twitter), may use cookies, web beacons, and other storage technologies to collect or receive information from our websites and elsewhere on the internet and use that information to provide measurement services and target ads. You can opt-in or opt-out of the collection and use of information for ad targeting using the website’s cookie consent manager (its Welcome! user interface pop-up windows or its cookie shaped icon) or the options described in the Opting Out section below. The tracking technologies we utilize include the following:

7.1              Cookies. We may use different types of cookies when providing different types of web-related services. If you do not know what cookies are, or how to control or delete them, then we recommend you visit www.aboutcookies.org for detailed guidance. Cookies allow us to identify and authenticate visitors, track aggregate behavior, and enable important service features. We use both session ID cookies and persistent cookies. Session ID cookies are used to maintain your browser state as you browse through services, and they expire when you close your browser. A persistent Cookie remains on your hard drive for an extended period, and we use that to identify you should you return to services and want to find information you had previously entered or accessed.

We may also contract with analytics services, third-party affiliate services, and third-party advertising companies to collect similar information. These cookies allow the ad servers to recognize your computer each time they send you an online advertisement, and compile information about you or others who use your computer. This information allows such Advertising Networks to, among other things, deliver targeted advertisements that they believe will be of most interest to you.

You may disable cookies through your web browser. For information about opting out of these collection services, please see the Opting Out section below.

7.2              Web Beacons/Tags. We may automatically collect aggregate anonymous information through files embedded in our services and emails known as “web beacons”. We may deliver a web beacon to you through our services from an Advertising Network with which we have contracted. Web beacons allow third parties to provide anonymized and aggregated auditing, research, and reporting for us. Web beacons also allow us to tell whether email recipients are able to properly view messages or if email messages have been opened, to ensure that we are sending only messages that are of interest to our users. We may use this information to reduce or eliminate messages sent to users. We do not tie the information gathered by web beacons to names or surnames.

7.3              Analytics. We may use analytics tools or similar tools provided by third parties (“Data Analytics Providers”) to help analyze how you and other users utilize the products, licenses, or services. Analytics tools use cookies and other tracking technologies to collect information such as how often users visit our website, what pages they visit, and what other websites they have used prior to visiting our website. We use the information we get from analytics tools only to improve products, licenses or services, to exercise or defend legal claims (if we know how many and where the visitors are residing, we can defend intellectual property rights -eg. trademarks which are territorial intellectual property rights, by providing evidence of their place and extent of use-), and to comply with applicable laws and regulations. Analytics tools collect the IP address or other unique identifier assigned to you on the date you visited services. We do not combine the information generated through the use of analytics tools with your name. Analytics tools provided by third parties plant a persistent cookie on your web browser to identify you as a unique user the next time you visit our website, and the treatment of that information is governed by the third party’s terms of use and/or privacy policy. To learn about how Google uses data related to website analytics when you use our website, click here: https://policies.google.com/technologies/partner-sites.

7.4              CAPTCHA. We may use CAPTCHA (Completely Automated Public Turing test to tell Computers and Humans Apart) or similar tools provided by third parties to secure the Site and apps. Our websites and apps use technologies such as a CAPTCHA, which prevents spam on websites and data scraping, and which collects and analyses your feedback to one or more tests or questions and/or your behavior. CAPTCHA tools collect your feedback (replies and/or behavior) to the test(s) assigned to you. As part of its CAPTCHA service, Google tells Guillemot that you are a human (to safeguard against intensive automated login attempts). We do not combine the information generated through the use of CAPTCHA tools with your other personal information. To learn about how Google protects privacy when you use Google’s CAPTCHA tools called reCAPTCHA, click here: https://policies.google.com/privacy?hl=en .

7.5              BY USING OUR WEBSITE, YOU GIVE CONSENT FOR US TO SHARE YOUR DATA WITH THESE THIRD PARTIES, AND FOR THEM TO TRANSFER THIS INFORMATION ONWARD TO THEIR PARTNERS IN CONNECTION WITH PROVIDING YOU SERVICES, EXCEPT TO THE EXTENT THAT YOU “OPT OUT” AS DESCRIBED BELOW.

8.                  OPTING OUT

You can make the following choices regarding your personal information:

8.1              Promotional and Other Emails. You may choose, during the account registration processes on one of our websites, or otherwise, to provide us with your email address for the purpose of allowing us to send newsletters, surveys, offers, and other materials related to our services. You can stop receiving these emails by sending a request via the contact form specified in the Contact Us section below or, if you subscribed to the newsletter(s) via your account, you can unsubscribe to one or more newsletters in the “Account Information” section, by unchecking the newsletter check box(es) and clicking on “SAVE”.

8.2              Behavioral Advertising. Our services may use behavioral advertising. This means that a third party may use technology (e.g., a cookie) to collect information about your use of our websites so that they can provide advertising about products and services tailored to your interests. That advertising may appear either on our website, or on other websites not operated by us. If you do not want third parties to collect information about your use of our services, you can opt-out of such at the Digital Advertising Alliance in the US, the Digital Advertising Alliance of Canada in Canada, or the European Digital Advertising Alliance in Europe. Alternatively, you may manage your choice through the website’s cookie consent manager (its Welcome! user interface pop-up windows or its cookie shaped icon); your choice applies only to the device from which you make the request because the cookie consent manager uses one or more cookies on that device to recognize your choice.

PLEASE NOTE THAT OPTING-OUT OF BEHAVIORAL ADVERTISING DOES NOT MEAN THAT YOU WILL NOT RECEIVE ADVERTISING WHILE USING SERVICES. IT WILL, HOWEVER, EXCLUDE YOU FROM INTEREST-BASED ADVERTISING CONDUCTED THROUGH PARTICIPATING NETWORKS, AS PROVIDED BY THEIR POLICIES AND CHOICE MECHANISMS.

8.3              Analytics. Many analytics providers allow end-users to opt out of the retention of their information, including our third-party analytics providers. You can manage your choice through the website’s cookie consent manager (its Welcome! user interface pop-up windows or its cookie shaped icon). Please note that, typically, unless you create an account with the analytics provider, your choice to opt out applies only to the device from which you make the request, because the providers use cookies on that device to recognize your choice. If you get a new device, install a new web browser, update your browser, or otherwise erase/alter your browser cookie files you may clear the opt-out cookie.

You may learn more about the use of information by and opting-out of analytics from our third-party provider by visiting its opt-out page at the following links:

www.google.com/policies/privacy/partners/

https://tools.google.com/dlpage/gaoptout

8.4              Cookies. You may disable, or delete certain cookies in your Web browser, but doing so may impact the usability of the website. To block cookies, you can also browse the Site using your browser’s anonymous usage setting (called “Incognito” in Chrome, “InPrivate” for Microsoft Edge, “Private Browsing” in Firefox and Safari, etc.). To block the cookies which are not “Strictly Necessary Cookies”, you may use the website’s cookie consent manager (its Welcome! user interface pop-up windows or its cookie shaped icon) to manage your consent to the use of cookies.  

8.5              Do Not Track. Our website does not recognize and respond to “Do Not Track” requests available through certain web browsers.

9.                  INTERNATIONAL TRANSFERS OF INFORMATION

Your personal information may be processed in the country in which it was collected and in other countries, where laws regarding personal information may be less stringent than the laws in your country.  Therefore, in some circumstances, you might be left without a legal remedy in the event of a privacy breach or other use that is prohibited in your country. By submitting your personal information, you agree to this transfer, storage and/or processing, including all associated risks.

10.              INFORMATION SECURITY

No method of transmission over the Internet, or method of electronic storage, is 100% secure. Therefore, we cannot guarantee its absolute security. We make efforts to protect your personal information from improper or unauthorized loss, misuse, access, disclosure, alteration, or destruction. If you have questions about the security of your personal information, contact us via the contact form specified in the Contact Us section below.

11.              DATA RETENTION

We will retain your personal information for as long as necessary to fulfill the purposes for which we collected it, including for the purposes of satisfying any legal, accounting, or reporting requirements. To determine the appropriate retention period for personal information, we consider the amount, nature, and sensitivity of the personal information, the potential risk of harm from unauthorized use or disclosure of your personal information, the purposes for which we process your personal information, whether we can achieve those purposes through other means, and the applicable legal requirements.

12.              THIRD-PARTY LINKS

Our websites or apps may contain links to other websites or apps. We are not responsible for the privacy practices or the content of these other websites or apps. You should read the policy statement of these other websites or apps to understand their policies. When you access linked websites or apps, you may be disclosing private information. It is your responsibility to keep -or not to keep- private and confidential such information.

13.              CHANGES TO THIS PRIVACY POLICY

We may update this Policy from time to time, in our sole discretion. When we do so, we will post the new Policy on our website. You should consult this Policy regularly for any changes. Continued use of services following posting of such changes constitutes your acknowledgement of such changes and agreement to be bound by the changes. If you do not agree, you should immediately discontinue your use of our website and services.

14.              CONTACT US

If you have questions regarding this Policy, its appendices, or our treatment of your personal information, you may contact us at:

            Guillemot Inc.

            6300 Av du Parc #440,

Montreal, QC, H2V 4H8

CANADA

            Attention: Legal Department

“Contact us” online form: either at https://support.hercules.com/en/contact-en/ or https://support.thrustmaster.com/en/contact-en/, sign in or create an account, then add a New query, select your country and region, and your language, then select the Category Support “Personal data”, then type a brief description of your request (here, you can type the following Title: “Privacy Policy Questions”), then please detail your question in the description field, then -if necessary- attach a document, and submit your query.

15.              APPEAL PROCESS

If you don’t have received any reply to your privacy right request, please check your request  - especially check the address if it was sent by post -  and rather send us a follow-up request than an appeal request. Please understand that we reserve our right not to respond to appeal requests submitted to any addresses other than the address required below, or not to the suitable addressee, or submitted more than once per calendar year.

If (a) you have exercised your privacy rights, and (b) you are not satisfied with our response to your privacy right request, you may file an appeal to our Data Privacy Officer by sending a letter by registered mail to:

            Guillemot Inc.

            6300 Av du Parc #440,

Montreal, QC, H2V 4H8

CANADA

            Attention: Data Privacy Officer (APPEAL)

Such appeal request must be either in English or French language and must include:

- your first name, last name, email address, mobile phone number, street address, city, state or province, zip code, and country;

- proof of your identity and address (e.g., a copy of your driving driver’s license or passport and a recent utility or credit card bill);

- a copy of your privacy right request ;

- information sufficient to enable us to identify the decision which is arguably not well founded (a copy of the decision or, at least, the decision date and its number);

- a list of the privacy right(s) that you arguably exercised through the privacy right request;

- a list of the privacy right(s) that were arguably not properly addressed by the decision;

- a clear statement of reasons explaining why the decision arguably violates the above listed privacy right(s); and

- a detailed description of your objectives (what is(are) all the result(s) you exactly want to reach).

Provided that the above requirements are all met, the appeal decision will be processed within forty-five days of receipt of your appeal request.

We also reserve our right not to respond to appeal requests submitted:

-          to addresses other than the address specified in this section 15;

-          by a shipment method which is not registered mail; and/or

-          submitted more than once per calendar year.

The appeal decision will be sent to the street address which appears on your proof of your identity and address.

APPENDIX USA - CALIFORNIA RESIDENT PRIVACY RIGHTS NOTICE

Last updated on: September 3, 2025

Your California Privacy Rights:

Under the California Consumer Privacy Act of 2018, as amended by the California Privacy Rights Act of 2020 and certain other privacy and data protection laws, as applicable, residents of California have the right to request that we disclose what personal information we collect, use, disclose, and sell. More specifically, if you are a resident of California you have rights to the following without charge:

Disclosure of Personal Information We Collect About You

You have the right to know the categories of personal information we have collected about you, the categories of sources from which we collect personal information, our business or commercial purpose for collecting or selling personal information, the categories of third parties with whom we share personal information, if any, and the specific pieces of personal information we have collected about you.

We reserve our rights to (i) not retain any personal information about you that was collected for a single one-time transaction if, in the ordinary course of business, that information about customers is not retained; (ii) not reidentify or otherwise link any data that, in the ordinary course of business, is not maintained in a manner that would be considered personal information; and (iii) not provide personal information to you more than twice in a 12-month period.

Disclosure of Personal Information Sold or Used for a Business Purpose

In connection with personal information we may sell or disclose for a business purpose, if any, you have the right to know the categories of personal information about you that we sold and the categories of third parties to whom we sold the personal information, and the categories of personal information that we disclosed about you for a business purpose.

Deletion of Personal Information

Subject to the exceptions set out below, and upon your submission of a verifiable request, you have the right to deletion of your personal information from our records, and to have us direct our service providers to delete your personal information from their records.

We are not required to, and reserve our right to not delete your personal information if it is necessary to: (i) complete the transaction for which the personal information was collected, fulfill the terms of a written warranty or product recall conducted in accordance with federal laws, provide a good or service requested by you, or reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform a contract between you and us; (ii) help to ensure security and integrity to the extent the use of your personal information is reasonably necessary and proportionate for those purposes; (iii) debug to identify and repair errors that impair existing intended functionality; (iv) exercise free speech, ensure the right of another customer to exercise his or her right of free speech, or exercise another right provided for by law; (v) comply with the California Electronic Communications Privacy Act; (vi) engage in public or peer-reviewed scientific, historical, or statistical research that conforms or adheres to all other applicable ethics and privacy laws, when our deletion of the information is likely to render impossible or seriously impair the achievement of such research, provided we have obtained your informed consent; (vii) enable solely internal uses that are reasonably aligned with your expectations based on your relationship with us and compatible with the context in which you provided the information; (viii) comply with a legal obligation; and (ix) comply with federal, state or local laws or comply with a court order or subpoena to provide information; (x) comply with a civil, criminal, or regulatory inquiry, investigation, subpoena or summons by federal, state or local authorities; (xi) cooperate with law enforcement agencies concerning conduct or activity that we, a service provider or third party reasonably and in good faith believes may violate federal, state or local laws; (xii) cooperate with a government agency request for emergency access to your personal information if a natural person is at risk or danger of death or serious physical injury; (xiii) exercise or defend legal claims.

Without limiting the foregoing, we will maintain a record of your request.

Freedom from Discrimination

You have the right to not be discriminated against by us because you exercised any of your rights under the California Consumer Privacy Act. This means we cannot, on the basis of the exercise of your rights thereunder, among other things, deny goods or services to you, charge different prices or rates for goods or services, including through the use of discounts or other benefits or imposing penalties; provide a different level or quality of goods or services to you; or suggest that you will receive a different price or rate for goods or services or a different level or quality of goods or services.

How to Exercise Your Rights

Unless otherwise specified, to exercise any of your California resident privacy rights described in this Appendix, please or submit your request to us at our telephone number (929) 900-1628 or either at https://support.hercules.com/en/contact-en/ or at https://support.thrustmaster.com/en/contact-en/, sign in or create an account, then add a New query, select your country and region, and your language, then select the Category Support “Personal data”, then type the Title “California CCPA Consumer Request”, then please detail your request in the description field, then attach -except for a request to only unsubscribe to our newsletters- your proof of identity and address, and submit your query.

In order to verify your request, you will need to provide us with enough information to identify you (e.g., your full name, address, and customer or matter reference number), proof of your identity and full address (e.g., a copy of  driver’s license or passport and a recent utility or credit card bill), and a description of what right you wish to exercise along with any information to which your requests relates.

You may also designate an authorized agent to make a request under the California Consumer Privacy Act on your behalf. In order to fulfill your request to know or delete submitted by an authorized agent, you must provide the authorized agent written permission to do so, and we may require you verify your own identity with us directly.

We reserve our right not to grant a consumer request if we cannot verify that the person making the request is the person about whom we have collected information, or someone authorized to act on such person’s behalf. You may only make a request to access or receive copies of personal information twice within a 12-month period. Any personal information we collect from you to verify your identity in connection with your request will be used solely for the purposes of verification.

Your Right to Opt-Out of the Sale of Personal Information

We may share your personal information to Advertising Networks that in addition to providing services to us will also use such information for their own purposes such as building consumer profiles for targeted behavioral advertising.  Under the CCPA, such sharing is considered to be a “sale”.

The best way to avoid the sale of personal information is to refrain from accepting any of the cookies which, by default, are not active. Accordingly, if you don’t want the sale of personal information, you should select “Reject All” the cookies in website’s cookie consent manager, in such a way to avoid the use of all non-essential cookies. By using the website’s cookie consent manager (its Welcome! user interface pop-up windows or its cookie shaped icon), you can obtain information regarding the cookies and activate only cookies which are acceptable for you.

You have the right to opt-out of the sale of your personal information.  You may exercise your right to opt-out by clicking on the Do not sell my personal information link which also appears in the footer of our webpages.  If you exercise your right to opt-out of the sale of your personal information, we will refrain from selling your personal information, unless you subsequently provide express authorization for the sale of your personal information.

Children’s Right to Opt-In to the Sale of Personal Information

We do not knowingly sell our products to or collect personal information from consumers who are not adults. On the contrary, each person who creates an account on our websites must represent and warrant having reached the age of legal majority.

If we were discover that we have collected and possess personal information of a customer under the age of 18, we would not sell the personal information of a customer under 16 years of age without affirmative authorization. We do not accept creation of an account by a minor even for minors who would wish to opt-in to the sale of their personal information.

Our Collection and Disclosure of Personal Information

Sources from Which We Receive Personal Information

We receive personal information from the following categories of sources:

·         You (including the customer, the individual involved in a business relationship with us, the newsletter subscriber, the social media member, the participant to a contest or sweepstake, the respondent to a survey, the website visitor, the user, the team member of our business or the Guillemot Companies),

·         Other team members,

·         Your representatives,

·         Fulfillment Providers,

·         Service Providers,

·         Commercial data providers,

·         Data Analytics Providers,

·         Other Business-to-Business relationship,

·         Social networks,

·         Employment providers,

·         Public entities,

·         Publicly accessible sources.

Third Parties with Whom We Share Personal Information

We routinely share personal information with the following categories of third parties:

·         Guillemot Companies,

·         Fulfillment Providers,

·         Data Analytics Providers,

·         Advertising Networks,

·         Service Providers

·         Public entities,

·         Auditors,

·         Operating systems and platforms,

·         Social networks,

·         Other team members,

·         Other Business-to-Business relationship,

·         Public (eg. published on Website, on social networks, …).

The following are Categories of Personal Information Collected, Disclosed, and Sold within the past 12 months or which we intend to collect, disclose or sell in the next 12 months.

The following are Categories of “sensitive” Personal Information Collected, Shared and Sold within the past 12 months for Cross-Context Behavioral Advertising or which we intend to collect, share or sell in the next 12 months for Cross-Context Behavioral Advertising; and Categories of “sensitive” Personal Information Collected and Disclosed for a Business Purpose within the past 12 months or which we intend to collect and disclose for a Business Purpose in the next 12 months.

Individual consumers who reside in California and have provided us with their personal information may request information about our disclosures of certain categories of personal information to third parties for their direct marketing purposes. Such requests must include your first name, last name, email address, street address, city, state, and zip code, and be submitted to us at one of the following addresses: online either at https://support.hercules.com/en/contact-en/ or at https://support.thrustmaster.com/en/contact-en/, please add a new query, select your country and region and your language, then select the Category Support “Personal data”, then type the Title “California Shine The Light Request” and a detailed description of your request, or by registered mail to Guillemot Inc. 6300 Av du Parc #440, Montreal, QC, H2V 4H8, Canada, Attention: Legal Department. Within thirty days of receiving such a request, we will provide a list of the categories of personal information disclosed to third parties for third-party direct marketing purposes during the immediately preceding calendar year, along with the names and addresses of these third parties. This request may be made no more than once per calendar year. We reserve our right not to respond to requests submitted to addresses other than the addresses specified in this paragraph.

If you are a California resident under the age of 18, and a registered user of any website where this Policy is posted, you are in material breach of our Terms of Use (because each person who creates an account on our website must represent and warrant having reached the age of legal majority). California Business and Professions Code Section 22581 permits to request and obtain removal of content or information that you have publicly posted. To make such a request, please ask your legal representative to contact us via the online contact form either at https://support.hercules.com/en/contact-en/ or at https://support.thrustmaster.com/en/contact-en/, add a new query, select your country and region and your language, then select the Category Support “Personal data”, then type the Title “Privacy Rights for Minors” and a detailed description of the specific content or information for which you want your legal representative to obtain the removal. Please be aware that such a request does not ensure complete or comprehensive removal of the content or information you have posted and that there may be circumstances in which the law does not require or allow removal even if requested.

APPENDIX USA - NEVADA RESIDENT PRIVACY RIGHTS NOTICE

Last updated on: October 1, 2025

Under Nevada Revised Statutes Sections 603A., et. seq. (the “Nevada Privacy Notice Law”), residents of Nevada have certain rights with respect to the “covered information” (namely, first and last name, home or other physical address, electronic mail address, telephone number, social security number, an identifier and another other information concerning a person and maintained by us in combination with an identifier that makes the information personally identifiable) that we collect on this website.

1.         The categories of personal information that we collect and the categories of third parties with whom we share personal information are described in the chart in the above California Resident Privacy Rights Notice.

2.         You may review and request changes to the “covered information” we collect or process on this website by contacting us via an online contact form either at https://support.hercules.com/en/contact-en/ or at https://support.thrustmaster.com/en/contact-en/, sign in or create an account, then add a New query, select your country and region, and your language, then select the Category Support “Personal data”, then type the Title “Nevada request change to collected information”, then please detail your request in the description field, then attach your proof of identity and address, and submit your query.

3.         Any material changes to this notice shall be posted in this Appendix to the Policy.

4.         When you use our website, we may share personal information about your online activities over time and across different internet sites or online services with third parties.

5.         You may make a request to us to refrain from “selling” (namely, exchanging for monetary consideration) your “covered information” by contacting us via the contact form either at https://support.hercules.com/en/contact-en/ or at https://support.thrustmaster.com/en/contact-en/, sign in or create an account, then add a New query, select your country and region, and your language, then select the Category Support “Personal data”, then type the Title “Nevada request to refrain from selling information”, then please detail your request in the description field, and submit your query.  Upon verification of the authenticity of your request and your identity using commercially reasonable means, we shall cease “selling” your “covered information” if we were selling it.

APPENDIX CANADA – ALBERTA RESIDENT PRIVACY RIGHTS NOTICE

Last updated on: October 1, 2025

Under the Alberta’s Personal Information Protection Act, residents of Alberta may have certain rights with respect to the personal information that Guillemot collects.

The individual responsible for ensuring that Guillemot complies with the Alberta’s Personal Information Protection Act is Mr. Claude Guillemot who is also President and whose business address is 2 rue du Chêne Héleuc, 56910 Carentoir, France.

You may exercise your Alberta resident privacy rights via the contact form either at https://support.hercules.com/en/contact-en/ or at https://support.thrustmaster.com/en/contact-en/, sign in or create an account, then add a New query, select your country and region, and your language, then select the Category Support “Personal data”, then type the Title “Alberta personal data request”, then please detail your request in the description field, then attach -except for a request to only unsubscribe to our newsletters- your proof of identity and address, and submit your query. Upon verification of the authenticity of your request and your identity, we shall process your Alberta resident privacy right request. The official languages that may be used to communicate with Guillemot are French and English.

We use the services of Fulfillment Providers and Service Providers, as defined in section 6 above, which are outside Canada, i.e. in the USA, Bulgaria, France, Germany, Ireland, Israel, United Kingdom, Singapore, Spain, and Sweden.

Purchase Data is collected, used, disclosed or stored by the Fulfillment Providers and Service Providers for the management of existing and prospective customers, especially for the purposes of:

- managing a database of existing and prospective customers;

- carrying out customer management activities concerning contracts, orders, pre-orders, subscriptions, shipping, billing and loyalty programs, undertaking customer relationship management activities such as satisfaction surveys and selecting existing or prospective customers to take part in studies, surveys and product tests;

- producing business statistics; and

- managing reviews of products, services and/or content.

Experience Data is collected, used, disclosed or stored by the Fulfillment Providers for the purposes of:

- managing the collection and retention of testimonials about people’s experience of products, services and/or content; and

- managing the publication of experiences.

Business-to-Business Data is collected, used, disclosed or stored by the Fulfillment Providers and Service Providers for the purposes of:

- managing purchases, orders, or sales;

- carrying out management activities concerning contracts, shipping, receipt-delivery, customs, return merchandise authorizations, billing;

- managing loyalty programs, undertaking customer relationship management activities such as satisfaction surveys and selecting existing or prospective customers to take part in studies, and surveys;

- managing sales forces;

- managing logistics;

- requesting or providing business information, business training;

- requesting or providing marketing support;

- requesting or providing technical support, training, and/or documentation;

- carrying out prospecting activities;

- selecting one or more categories of people to take part in loyalty campaigns, prospecting activities, studies, surveys, product testing and promotional campaigns and undertaking marketing campaigns;

- organizing competitions, lotteries and promotional campaigns of any kind; and

- producing business statistics.

Accounting Data collected is collected, used, disclosed or stored by the Fulfillment Providers and Service Providers for the purposes of:

- managing payments;

- avoiding fraud, impersonation;

- fulfilling tax and accounting obligations;

- managing outstanding amounts, reminders and arrears;

- archiving and supplying accounting records; and

- managing audits.

After-Sale Service Data is collected, used, disclosed or stored by the Fulfillment Providers and Service Providers for the purposes of:

- managing document libraries (templates) and contacts;

- producing statistics;

- managing warranty claims; and

- managing requests to exercise the right of withdrawal.

Newsletter Data is collected, used, disclosed or stored by the Fulfillment Providers and Service Providers for the purposes of: sending newsletters.

Social Data is collected, used, disclosed or stored by the Fulfillment Providers and Service Providers for the purposes of:

- interacting with social media subscribers;

- sending information to social media subscribers; and

- managing social media distribution channels.

Contest and Sweepstakes Data is collected, used, disclosed or stored by the Fulfillment Providers and Service Providers for the purposes of:

- organizing contests, sweepstakes, competitions, lotteries, and promotional campaigns of any kind;

- organizing marketing events; and

- producing statistics.

Survey Data is collected, used, disclosed or stored by the Fulfillment Providers and Service Providers for the purposes of:

- undertaking customer relationship management;

- selecting existing or prospective customers;

- organizing studies or product tests; and

- obtaining evidence for litigation matters.

Use Data is collected, used, disclosed or stored by the Fulfillment Providers and Service Providers for the purposes of:

- measuring website audiences and monitoring website activity;

- improving access to websites;

- improving website security;

- advertising;

- managing the operation of websites and servers;

- technically administering websites;

- securing websites through event logging; and

- producing statistics.

Team Data is collected, used, disclosed or stored by the Fulfillment Providers and Service Providers for the purposes of:

- staff recruitment, administration and management, mandatory employment control, individual employment contract, job description, revisal);

- payments to team members (salary, internship allowance, reimbursement of expenses, etc.);

- logistics (processing of information regarding the sender, the receiver and the content type);

- management of corporate matters (administrative formalities, company book handling, etc.);

- management of stock options; and

- IT security (including data security).

User Access Data is collected, used, disclosed or stored by the Fulfillment Providers and Service Providers for the management of user access is processed, especially for the purposes of:

- verifying access rights; and

- combating illegitimate use.

Legal Data is collected, used, disclosed or stored by the Fulfillment Providers and Service Providers for the purposes of managing actual and potential litigation and pre-litigation matters and responding to requests from authorities (or courts), especially for:

- gathering the required information (eg. evidence);

- managing potential litigation;

- managing pre-litigation matters;

- managing litigation;

- managing archived pre-litigation and litigation files; and

- executing decisions.

We also use the services of Guillemot Companies which are each a “service provider”, as defined by the Alberta’s Personal Information Protection Act, to collect, use, disclose or store personal information for or on behalf of us. Guillemot Companies are in France, Romania, and in Hong-Kong.

Purposes for which personal information is collected, used, disclosed or stored by the Guillemot Companies

Purchase Data is collected, used, disclosed or stored by the Guillemot Companies for the management of existing and prospective customers, especially for the purposes of:

- managing a database of existing and prospective customers;

- carrying out customer management activities concerning contracts, orders, pre-orders, subscriptions, shipping, billing and loyalty programs, undertaking customer relationship management activities such as satisfaction surveys and selecting existing or prospective customers to take part in studies, surveys and product tests;

- carrying out prospecting activities;

- selecting one or more categories of people to take part in loyalty campaigns, prospecting activities, studies, surveys, product testing and promotional campaigns and undertaking marketing campaigns;

- producing business statistics;

- organizing competitions, lotteries and promotional campaigns of any kind;

- preparing and publishing content;

- managing reviews of products, services and/or content;

- improving products, services and/or content; and

- managing your favorite content, products and/or services.

Experience Data is collected, used, disclosed or stored by the Guillemot Companies for the purposes of:

- managing the collection and retention of testimonials about people’s experience of products, services and/or content; and

- managing the publication of experiences.

Business-to-Business Data is collected, used, disclosed or stored by the Guillemot Companies for the purposes of:

- managing a database of existing and prospective customers;

- managing a database of existing and prospective service providers;

- managing a database of existing and prospective suppliers;

- managing purchases, orders, or sales;

- carrying out management activities concerning contracts, shipping, receipt-delivery, customs, return merchandise authorizations, billing;

- managing loyalty programs, undertaking customer relationship management activities such as satisfaction surveys and selecting existing or prospective customers to take part in studies, and surveys;

- managing quotas;

- managing sales forces;

- managing, generating, providing, or requesting forecasts;

- managing logistics;

- requesting or providing business information, business training;

- requesting or providing marketing support;

- requesting or providing technical support, training, and/or documentation;

- managing quality assurance;

- carrying out prospecting activities;

- selecting one or more categories of people to take part in loyalty campaigns, prospecting activities, studies, surveys, product testing and promotional campaigns and undertaking marketing campaigns;

- organizing competitions, lotteries and promotional campaigns of any kind;

- producing business statistics; and

- improving offers and/or services.

Accounting Data collected is collected, used, disclosed or stored by the Guillemot Companies for the purposes of:

- managing payments;

- managing securities;

- managing the cash flow;

- avoiding fraud, impersonation;

- maintaining accounting records;

- fulfilling tax and accounting obligations;

- organizing the accounting system;

- managing outstanding amounts, reminders and arrears;

- optimizing the company’s physical and financial performance (financial control);

- providing figures;

- archiving and supplying accounting records; and

- managing audits.

After-Sale Service Data is collected, used, disclosed or stored by the Guillemot Companies for the purposes of:

- assigning requests;

- responding to requests and ensuring they are followed up;

- supervising processes so as to understand and optimize the activities of the department responsible for processing requests and complaints;

- interacting with existing and prospective customers;

- managing document libraries (templates) and contacts;

- producing statistics;

- managing uncivil conduct towards staff;

- managing warranty claims;

- managing requests to exercise the right of withdrawal;

- managing requests to exercise the rights to access and correct data and object to its processing (data protection rights) and, more generally, requests to exercise any other rights;

- enabling internet users to contact Guillemot online and track their requests;

- enabling internet users to easily access their data;

- enabling internet users to easily update their data;

- providing a secure communication channel; and

- reporting of bugs and other technical issues.

Newsletter Data is collected, used, disclosed or stored by the Guillemot Companies for the purposes of:

- managing subscriptions; and

- creating and using email distribution lists.

Social Data is collected, used, disclosed or stored by the Guillemot Companies for the purposes of:

- interacting with social media subscribers;

- sending information to social media subscribers; and

- managing social media distribution channels.

Contest and Sweepstakes Data is collected, used, disclosed or stored by the Guillemot Companies for the purposes of:

- organizing contests, sweepstakes, competitions, lotteries, and promotional campaigns of any kind;

- organizing marketing events;

- obtaining material to illustrate or promote products, licenses, or services offered by Guillemot or Guillemot Companies; and

- producing statistics.

Survey Data is collected, used, disclosed or stored by the Guillemot Companies for the purposes of:.

- undertaking customer relationship management;

- selecting existing or prospective customers;

- organizing studies or product tests;

- improving products, services and/or content; and

- obtaining evidence for litigation matters.

Use Data is collected, used, disclosed or stored by the Guillemot Companies for the purposes of:

- measuring website audiences and monitoring website activity;

- producing statistics;

- improving access to websites;

- improving website security;

- advertising;

- managing the operation of websites and servers;

- technically administering websites;

- securing websites through event logging; and

- producing statistics.

Team Data is collected, used, disclosed or stored by the Guillemot Companies for the purposes of:

- staff recruitment, administration and management, mandatory employment control, individual employment contract, job description, revisal);

-payments to team members (salary, internship allowance, reimbursement of expenses, etc.);

- conduct of employment relationships;

- team members’ safety and health (application of legal provisions);

- safety of persons and property of employees and the Company;

- provision of Guillemot’s team members with IT tools;

- logistics (processing of information regarding the sender, the receiver and the content type);

- corporate communications;

- internal communications;

- management of corporate matters (administrative formalities, company book handling, etc.);

- management of stock options; and

- IT security (including data security).

User Access Data is collected, used, disclosed or stored by the Guillemot Companies for the management of user access is processed, especially for the purposes of:

- creating access rights;

- verifying access rights;

- revoking or restricting access rights; and

- combating illegitimate use.

Legal Data is collected, used, disclosed or stored by the Guillemot Companies for the purposes of managing actual and potential litigation and pre-litigation matters and responding to requests from authorities (or courts), especially for:

- managing requests from authorities (or courts), including submitting responses;

- gathering the required information (eg. evidence);

- managing potential litigation;

- managing pre-litigation matters;

- managing litigation;

- managing archived pre-litigation and litigation files;

- executing decisions; and

- producing statistics.

APPENDIX CANADA – BRITISH COLUMBIA PRIVACY RIGHTS NOTICE

Last updated on: October 1, 2025

Under the British Columbia’s Personal Information Protection Act, residents of British Columbia may have certain rights with respect to the personal information that Guillemot collects.

The individual responsible for ensuring that Guillemot complies with the British Columbia’s Personal Information Protection Act is Mr. Claude Guillemot who is also President and whose business address is 2 rue du Chêne Héleuc, 56910 Carentoir, France.

You may exercise your British Columbia resident privacy rights (right to access or correct an error or omission in your personal information (under the British Columbia’s Personal Information Protection Act) via the contact form either at https://support.hercules.com/en/contact-en/ or at https://support.thrustmaster.com/en/contact-en/, sign in or create an account, then add a New query, select your country  and region, and your language, then select the Category Support “Personal data”, then type the Title “British Columbia personal data request”, then please detail your request in the description field, then attach -except for a request to only unsubscribe to our newsletters- your proof of identity and address, and submit your query. Upon verification of the authenticity of your request and your identity, we shall process your British Columbia resident privacy right request. The official languages that may be used to communicate with Guillemot are French and English.

Further information regarding how personal information is collected

Personal information is collected by forms to be filled in by you (contact forms, account creation form, registration forms, request forms, subscription forms) on the Site, apps, or social media.

Personal information may be recorded based on your actions (eg. the date of the last communication received from you, from which forms (source of data) your personal information come from). We determine whether you are a Thrustmaster customer, a Hercules customer, a DJUCED customer, an Ambassador and/or a VIP and we determine your status (“approved”, “pending”, etc.).

If we have your date of birth, we use it to determine your age and the date of your next birthday. If you have been the subject of a marketing campaign, we determine the date of the last campaign, the outcome, and whether or not you have consented to receive marketing materials. We track your consent including the timing of when it was given, the subject (e.g. subscription to a particular newsletter) and the type of consent given. Where applicable, we track your attendance at events including their name, type, and scheduled start date and time.

When you wish to participate in an activity or event that is covered by one or more contracts, we save precontractual or contractual representations (e.g. confirmation that you are of legal age and able to enter into contracts, read, understand and write correctly in one or more languages, etc.). If you participate in the activity or event in question, we save the contract between you and us.

When you wish to participate in an activity or event that requires you to meet certain criteria (e.g. a product test), we collect information about your hardware and/or software setup.

If you participate in an activity or event, we may also collect information that you provide about yourself (to help us understand your feedback, for example by helping us determine whether or not your situation and/or your needs are specific to you), your participation in the activity or event (what you thought about it and any questions, comments, reports and answers about the activity or event, etc.).

If you introduce yourself to us, we may collect your bio, taste in music and/or video games, username (or nickname) on one or more social media and/or links (e.g. to your blog or social media), influences, musical plans, e-Sports plans and live dates.

When access needs to be restricted, we ask you for a password and we collect it.

If you contact us, we will collect information about your requests and complaints.

If you exercise your right to access or correct your personal information, we will collect a copy of proof of identification or additional information (to give Guillemot the information it needs to dispel any reasonable doubts it might have about your identity).

Guillemot also collects the messages, comments, replies and emails you send to Guillemot and a transcription of any voice conversations you have with us (including identifying information, timing, the identity of our agent and a transcription of the response given by our agent).

Personal information is collected by communication posted by you on social media.

Personal information is also obtained by Guillemot via the Guillemot Companies, via Fulfillment Providers, and via Service Providers.

The delivery service providers provide Guillemot with the dispatch date and shipping status as well as the routing information it needs to be able to keep the customer informed and respond to any shipping-related complaints.

A social media data collection provider (a marketing services provider) collects reviews posted on social media together with the reviewer’s username (or nickname) and Guillemot’s replies on social media and provides them to Guillemot. However, Guillemot directly collects anything you post in private areas created on social media by Guillemot.

Special case of payment information: Payment information such as card number, card expiration month and year, and verification code (CVC or CVV) is not collected by us even if it may seem to you that it is being collected by Guillemot. From one of the Fulfillment Providers (here, the reseller and merchant), Guillemot receives “Authorizes payment” information and a mostly redacted bank card or charge card number.

Cookies. Guillemot uses the information contained in cookies to more effectively track users and provide them with personalized content and functionality. Cookies are simply pieces of information sent from a web server and stored on your device (computer, smartphone, smart TV, connected gaming console, etc.). Cookies do not contain names or email addresses. Simply express your choice regarding cookies in the window that notifies you that the Site uses cookies. An icon is available allowing you to modify your cookie choices. While you can object to the use of cookies, you must understand that some of the Site’s pages and features may not work properly if your browser refuses cookies.

Other tracking. Guillemot tracks Internet Protocol (IP) addresses. An IP address is a unique number used by computers on the network to identify your device each time you connect to the internet. Guillemot collects limited information about your connection location (the geolocation data about your connection location is no more specific than town/city), your internet service provider (ISP), the type of device you are using (computer, telephone, etc.), the operating system (OS) you are using, the time at which you began browsing, the number of page(s) viewed, the specific page being viewed, and the browser language and web browser you are using.

If you arrive at the Site via an affiliate link, Guillemot collects the information corresponding to that link. Like many other websites, the Site passively collects and stores non-personally identifiable information in log files. This process records website activity, including the number of views for a specific web page. In cases where you are not required to log in to your account, these entries are generated in a non-personally identifiable way and are not associated with any specific user. In cases where you are required to log in to your account (to make online purchases, access non-public information, etc.), the data is associated with a specific user (the account-holder).

Description of the personal information that is collected and purposes for which personal information is collected

The personal information that we collect (Purchase Data, Experience Data, Business-to-Business Data, Accounting Data, After-Sale Service Data, Newsletter Data, Social Data, Contest and Sweepstakes Data, Survey Data, Use Data, Team Data, User Access Data, and Legal Data) are further described in the above sections 2 and 4 which generally apply (throughout the USA and Canada).

Purposes for which personal information is collected

Purchase data is collected for the management of existing and prospective customers, especially for the purposes of:

- managing a database of existing and prospective customers;

- carrying out customer management activities concerning contracts, orders, pre-orders, subscriptions, shipping, billing and loyalty programs, undertaking customer relationship management activities such as satisfaction surveys and selecting existing or prospective customers to take part in studies, surveys and product tests;

- carrying out prospecting activities;

- selecting one or more categories of people to take part in loyalty campaigns, prospecting activities, studies, surveys, product testing and promotional campaigns and undertaking marketing campaigns;

- producing business statistics;

- organizing competitions, lotteries and promotional campaigns of any kind;

- preparing and publishing content;

- managing reviews of products, services and/or content;

- improving products, services and/or content; and

- managing your favorite content, products and/or services.

Experience Data is collected for the purposes of:

- managing the collection and retention of testimonials about people’s experience of products, services and/or content; and

- managing the publication of experiences.

Business-to-Business Data is collected for the purposes of:

- managing a database of existing and prospective customers;

- managing a database of existing and prospective service providers;

- managing a database of existing and prospective suppliers;

- managing purchases, orders, or sales;

- carrying out management activities concerning contracts, shipping, receipt-delivery, customs, return merchandise authorizations, billing;

- managing loyalty programs, undertaking customer relationship management activities such as satisfaction surveys and selecting existing or prospective customers to take part in studies, and surveys;

- managing quotas;

- managing sales forces;

- managing, generating, providing, or requesting forecasts;

- managing logistics;

- requesting or providing business information, business training;

- requesting or providing marketing support;

- requesting or providing technical support, training, and/or documentation;

- managing quality assurance;

- carrying out prospecting activities;

- selecting one or more categories of people to take part in loyalty campaigns, prospecting activities, studies, surveys, product testing and promotional campaigns and undertaking marketing campaigns;

- organizing competitions, lotteries and promotional campaigns of any kind;

- producing business statistics; and

- improving offers and/or services.

Accounting Data collected is collected for the purposes of:

- managing payments;

- managing securities;

- managing the cash flow;

- avoiding fraud, impersonation;

- maintaining accounting records;

- fulfilling tax and accounting obligations;

- organizing the accounting system;

- managing outstanding amounts, reminders and arrears;

- optimizing the company’s physical and financial performance (financial control);

- providing figures;

- archiving and supplying accounting records; and

- managing audits.

After-Sale Service Data is collected for the purposes of:

- assigning requests;

- responding to requests and ensuring they are followed up;

- supervising processes so as to understand and optimize the activities of the department responsible for processing requests and complaints;

- interacting with existing and prospective customers;

- managing document libraries (templates) and contacts;

- producing statistics;

- managing uncivil conduct towards staff;

- managing warranty claims;

- managing requests to exercise the right of withdrawal;

- managing requests to exercise the privacy rights to access and correct data and, more generally, requests to exercise any other rights;

- enabling internet users to contact Guillemot online and track their requests;

- enabling internet users to easily access their data;

- enabling internet users to easily update their data;

- providing a secure communication channel; and

- reporting of bugs and other technical issues.

Newsletter Data is collected for the purposes of:

- managing subscriptions; and

- creating and using email distribution lists.

Social Data is collected for the purposes of:

- interacting with social media subscribers;

- sending information to social media subscribers; and

- managing social media distribution channels.

Contest and Sweepstakes Data is collected for the purposes of:

- organizing contests, sweepstakes, competitions, lotteries, and promotional campaigns of any kind;

- organizing marketing events;

- obtaining material to illustrate or promote products, licenses, or services offered by Guillemot or Guillemot Companies; and

- producing statistics.

Survey Data is collected for the purposes of:

- undertaking customer relationship management;

- selecting existing or prospective customers;

- organizing studies or product tests;

- improving products, services and/or content; and

- obtaining evidence for litigation matters.

Use Data is collected for the purposes of:

- measuring website audiences and monitoring website activity;

- producing statistics;

- improving access to websites;

- advertising;

- managing the operation of websites and servers;

- technically administering websites;

- securing websites through event logging; and

- producing statistics.

Team Data is collected for the purposes of:

- staff recruitment, administration and management, mandatory employment control, individual employment contract, job description, revisal;

- payments to team members (salary, internship allowance, reimbursement of expenses, etc.);

- conduct of employment relationships;

- team members’ safety and health (application of legal provisions);

- safety of persons and property of employees and the Company;

- provision of Guillemot’s team members with IT tools;

- logistics (processing of information regarding the sender, the receiver and the content type);

- corporate communications;

- internal communications;

- management of corporate matters (administrative formalities, company book handling, etc.);

- management of stock options; and

- IT security (including data security).

User Access Data collected in connection with the management of user access is processed for the purposes of:

- creating access rights;

- verifying access rights;

- revoking or restricting access rights; and

- combating illegitimate use.

Legal Data is collected for the purposes of managing actual and potential litigation and pre-litigation matters and responding to requests from authorities (or courts), especially for:

- managing requests from authorities (or courts), including submitting responses;

- gathering the required information (eg. evidence);

- managing potential litigation;

- managing pre-litigation matters;

- managing litigation;

- managing archived pre-litigation and litigation files;

- executing decisions; and

- producing statistics.