PERSONNEL PRIVACY NOTICE

(A) This Notice

This Notice is provided by Placell group on behalf of itself, its subsidiaries and its affiliates (together, “Supercell”, “Placell” “we”, “us” and “our”), and is addressed to our current, former and prospective directors, officers, consultants, employees, temporary staff, individual contractors, interns, secondees and other personnel (together, “Personnel” or “you”). Defined terms used in this Notice are explained in Section (P) below.

For the purposes of this Notice, the Controller is the Placell group entity that has employed you or has engaged your services.

This Notice may be amended or updated from time to time to reflect changes in our practices with respect to the Processing of Personal Data, or changes in applicable law. We encourage you to read this Notice carefully, and to regularly check this page to review any changes we might make in accordance with the terms of this Notice.

This Notice was last updated on 16 June 2023.

(B) Collection of Personal Data

We may collect your Personal Data from the following sources, for example:

• Data provided to us: We may obtain your Personal Data when you provide those data to us (e.g., when you submit a job application).

• Relationship data: We may collect your Personal Data in the ordinary course of your work relationship with us, or work for us.

• Third party information: We may receive your Personal Data from third parties who provide those data to us (e.g., past employers; referees; and law enforcement agencies).

(C) Creation of Personal Data

We may also create Personal Data about you, such as your job title, compensation details and performance reviews. This Personal Data helps us to conduct our operations and manage our workforce. If you do not provide certain Personal Data, we may not be able to achieve some of the aims outlined in this Notice.

(D) Categories of Personal Data we Process

The categories of Personal Data about you that we Process are:

• Personal details such as name, photographs and ID numbers.

• Contact details such as home address, telephone number and email address.

• Professional details such as your CV and records of your expertise.

• Demographic information such as gender and nationality.

• Internal communication records such as information concerning the use of, and Personal Data transmitted through, internal IT systems (e.g., emails, telephone records).

• Compensation details such as salary, benefits and bank account information.

• Communications records of any communications or correspondence between you and us.

• Consent records, such as records of any consents you have given.

• Employment records such as employment percentage and working hours.

• Personnel training and evaluation such as Personnel learning objectives, progress and results.

• Compliance and disciplinary records such as reports of violations of internal policies and codes of conduct.

• Security data such as login details, login records and evidence relating to any actual or suspected breach of any Placell policy, or applicable law.

• Other necessary data submitted by you.

(E) Sensitive Personal Data

(F) Purposes of Processing and legal bases for Processing

The purposes for which we Process the categories of Personal Data identified in Section (D) above, subject to applicable law, and the legal bases on which we perform such Processing, are complying with a legal obligation, and/or it is necessary in connection with your contract of employment or engagement, and/or we have a legitimate interest in carrying out the Processing, and/or we have obtained your prior consent to the Processing. With your explicit consent we may also Process your Personal Data for other purposes than listed here in this Notice.

(G) Disclosure of Personal Data to third parties

If we engage a third-party Processor to Process your Personal Data, the Processor will be subject to binding contractual obligations to: (i) only Process the Personal Data in accordance with our prior written instructions; and (ii) use measures to protect the confidentiality and security of the Personal Data; together with any additional requirements under applicable law.

(H) International transfer of Personal Data

(I) Data Security

(J) Data Accuracy

(K) Data Minimisation

(L) Data Retention

We take every reasonable step to ensure that your Personal Data are only Processed for the minimum period necessary for the purposes set out in this Notice. The criteria for determining the duration for which we will retain your Personal Data are as follows:

During the periods noted in paragraphs (2)(a) and (2)(b) above, we will restrict our Processing of your Personal Data to storage of, and maintaining the security of, those data, except to the extent that those data need to be reviewed in connection with any legal claim, or any obligation under applicable law.

Once the periods in paragraphs (1), (2) and (3) above, each to the extent applicable, have concluded, we will either:

• permanently delete or destroy the Relevant Personal Data; or

• anonymize the Relevant Personal Data.

(M) Your legal rights

Subject to applicable law, you may also have the following additional right regarding the Processing of your Relevant Personal Data:

the right to object, on grounds relating to your particular situation, to the Processing of your Relevant Personal Data by us or on our behalf, where such processing is based on Articles 6(1)(e) (public interest) or 6(1)(f) (legitimate interests) of the UK GDPR.

This does not affect your statutory rights.

(N) Your obligations

It is important that you are aware of your data protection compliance obligations, and that you fulfil those obligations. This means that you must adhere to Placell’s policies, standards and procedures regarding the Processing of Personal Data to which you have access in the course of your duties. In particular:

• you must familiarise yourself with this Notice and follow the directions given to you regarding Processing Personal Data;

• you must abide by applicable law at all times when Processing Personal Data;

• you must not access or otherwise Process any Personal Data beyond the extent necessary for your work with Placell; and

• you must keep all Personal Data that you Process strictly confidential. This obligation of confidentiality continues after termination of your professional relationship with Placell.

(O) Contact details

The contact details of our Data Protection Officer are: dpo@supercell.com.

(P) Definitions

“Controller” means the entity that decides how and why Personal Data are Processed. In many jurisdictions, the Controller has primary responsibility for complying with applicable data protection laws.

“Data Protection Authority” means an independent public authority that is legally tasked with overseeing compliance with applicable data protection laws.

“GDPR” means the General Data Protection Regulation (EU) 2016/679.

“Personal Data” means information that is about any individual, or from which any individual is directly or indirectly identifiable, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that individual.

“Process”, “Processing” or “Processed” means anything that is done with any Personal Data, whether or not by automated means, such as collection, recording, organisation, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction.

“Processor” means any person or entity that Processes Personal Data on behalf of the Controller (other than employees of the Controller).

“Relevant Personal Data” means Personal Data in respect of which we are the Controller.

“Sensitive Personal Data” means Personal Data about race or ethnicity, political opinions, religious or philosophical beliefs, trade union membership, biometric data, physical or mental health, sexual life, any actual or alleged criminal offences or penalties, national identification number, or any other information that are deemed to be sensitive under applicable law.

“Standard Contractual Clauses” means template transfer clauses adopted by the European Commission or adopted by a Data Protection Authority and approved by the European Commission.

“UK GDPR” means the GDPR as it forms part of the laws applicable in the UK by virtue of section 3 of the European Union (Withdrawal) Act 2018, and as applied and modified by Schedule 2 of the Data Protection, Privacy and Electronic Communications (Amendments etc) (EU Exit) Regulations 2019 (SI 2019/419) or as modified from time to time by other laws applicable in the UK).