UBISOFT PRIVACY POLICY

UBISOFT PRIVACY POLICY

Ubisoft Inc. and or any one of its parent, subsidiary or affiliated companies, including without limitation, Ubisoft Entertainment Inc., Ubisoft Entertainment SA, Ubisoft EMEA SAS, Ubisoft Mobile Games, Red Storm Entertainment, Inc., and Blue Byte GMBH (collectively, "Ubisoft" or "we"), respect the privacy rights of our visitors and users (“users”) and recognize the importance of protecting all information that you may choose to share with us. To further this commitment, we have adopted this Privacy Policy (the “Policy”) to guide how we collect, store, use and share the information you provide us when you access Ubisoft's websites, mobile sites and applications, online games, online functions of offline games and any other online functions controlled, accessed by Ubisoft as described herein (collectively, the "Services"). If you do not agree to the terms of this Policy, please do not use the Services. We collect information only in the context of our business activity and to enable us to respond to your requests, pursuant to the Personal Information Protection and Electronic Documents Act (the “Act”).

We reserve the right to change the provisions of this Policy at any time. We will alert you that changes have been made by indicating on the Policy the date it was revised. We encourage you to review this Policy from time to time to make sure that you understand how any personal information you provide will be used. Your continued use of the Services following the posting of changes to these terms will mean you accept those changes.

This Policy and the certification seal shown on the Services confirm that Ubisoft is a member in good standing of ESRB's Privacy Certified Program. ESRB's Privacy Certified Program is designed to ensure that our Services’ information disclosure practices are responsible and appropriate. To protect your privacy, we have voluntarily undertaken this privacy initiative and the Services have been reviewed and certified by ESRB Privacy Certified to meet established online information collection and use practices. As part of this privacy program, we are subject to frequent audits of our Services and other enforcement and accountability mechanisms administered independently by the ESRB.

Table of Contents:

1. What is Personal Information?

2. When and how does Ubisoft collect Personal Information?

2.1 Does Ubisoft use cookies or other analytic tools to collect my Personal Information?

3. How does Ubisoft use Personal Information?

4. Does Ubisoft share Personal Information with third parties?

5. Does Ubisoft collect Personal Information from children under 13?

6. What if I refuse to provide Personal Information?

7. How long does Ubisoft use Personal Information?

8. How do I access and/or update my Personal Information?

9. What safeguards does Ubisoft use to protect Personal Information?

10. Does this Policy apply to other sites linked by the Services?

11. Ubisoft’s Terms of Use

12. How do I ask questions or send comments about this Policy?

1. What is Personal Information?

As used herein, the term "personal information" means information that specifically identifies any individual, (including without limitation, name, date of birth address, telephone/ mobile number, e-mail address or payment/billing information )and any other information that is required by applicable law to be treated as Personal Information(“Personal Information”).

Personal Information does not include "aggregate” or “anonymized” information", which is data we collect about a User’s, or group or category of Users’, use of the Services and/or other sites or services (including without limitation demographic or preference information) from which individual identities or other Personal Information has been removed. Please note, if Ubisoft combines this information with Personal Information, Ubisoft will treat this information as Personal Information pursuant to this Policy

2. When and how does Ubisoft collect Personal Information?

Pursuant to applicable law, Ubisoft collects your Personal Information at different times when you interact with our Services, buy our products or otherwise contact us. Generally, Personal Information is collected when (a) you create a user account, such as a Uplay account or other account on the Services (collectively an “Account”), (b) you create a public profile, (c) you shop at one of our online stores or purchase virtual items within a game, (d) you create user generated content, (e) you participate in interactive sections of the Services or watch advertisements within our Services, (f) you sign up to receive a newsletter or other promotional content, (g) you contact Ubisoft customer service or request technical support, (h) you participate in a contest, sweepstakes, event or promotion, (i) you participate in community forums or chat rooms, (j) you apply for a beta tester position, (k) register a product online or download patches or demos. Whatever the activity may be, we will only collect information to the extent deemed reasonably necessary to fulfil your requests and our legitimate business objectives.

We may obtain certain information about you from third parties, including Personal Information. Please note: Ubisoft is not responsible for the privacy and security practices and policies of such third parties.

2.1 Does Ubisoft use cookies or other analytic tools to collect my Personal Information?

Cookies: Ubisoft uses cookies on the Services. A "cookie" is a small bit of record-keeping information that web sites often store on a user's computer. Cookies do not include people's names, e-mail addresses, or other information that is personally identifiable; they are typically used to quickly identify a user's computer and to "remember" things about the user's visit. Ubisoft may set cookies for your web browser as you visit our websites, use our products or visit a website where Ubisoft provides ads, content or analytics. For example, Ubisoft uses cookies to keep track of selected items in your shopping cart and to remember your Account identifier. You can disable cookies or set your browser to alert you when cookies are being sent to your computer, although this may affect your ability to shop online or to access certain features of our Services. Each browser is different, so check the "Help" menu of your browser to learn how to change your cookie preferences. In addition to Ubisoft using cookies on our network of websites, Ubisoft allow certain partners to set and access their cookies on your computer. These companies use of cookies is subject to their own privacy policies, not the Ubisoft Privacy Policy. Please review them carefully. For more information about cookies, please see http://www.allaboutcookies.org.

IP addresses: Ubisoft also keep tracks of Internet Protocol (IP) addresses for safety and security reasons. An IP address is a number that is used by computers on the network to identify your computer every time you log on to the Internet.

Analytics Tools: Ubisoft may on its own, or with the help of third party analytics tools, collect information concerning your gaming habits, hardware and use of our products and Services. The information collected may contain the following, without limitation: device unique identity, including console, mobile, tablet and console unique identifier or other device identifiers and settings, internet provider, carrier, operating system, hardware information, localization information, date and time spent on the Services, game scores, game metrics and statistics, feature usage, advertising conversion rates, monetization rate, purchase history and other similar information.

Interest Based Ads: UBISOFT also uses third party ad serving technologies that may collect information as a result of ad serving in the products and Services, and that may temporarily display advertisements on the Services and third party sites. The information collected and used for the interest based advertising may contain the following, without limitation: age and gender, number views of an advertisement, device unique identity or other device identifiers and settings, information about your use of the products and Services and other Internet sites (including third party web pages and mobile Internet sites) viewed by you (as well as date and time viewed), advertisement(s) served, the advertisement(s)’ in game location and length, and response to the advertisement(s) (if any).

The analytics tools and ad serving technologies may use server log files, web beacons, cookies (as further described below), tracking pixels and other technologies to collect said information, and may combine the information collected on other Ubisoft products and services with information collected from other third party websites and mobile products and services and with demographic, advertisement, market and other analytics surveys. Standing alone, this information may not be Personal Information; however, if UBISOFT combines any of this information with Personal Information to serve you such interest based advertising, UBISOFT will provide you an opportunity to opt-out of such combination and treat this information as Personal Information pursuant to this Policy.

UBISOFT makes its best efforts to (a) provide you with the list of partners whose cookies, analytic tools and/or ad serving technologies are used in our Services, (b) links to these partners’ own privacy policies according to which their tools and technologies are used, and (c) when available, to provide you with a link to allow you to opt-out from these partners’ services. To that end, you will find such non-exhaustive list here: https://legal.ubi.com/cookies/. Alternatively, you can opt out of some third-party technology’s use of cookies for interest-based advertising by visiting aboutads.info.

3. How does Ubisoft use Personal Information?

We don't require Personal Information to access our Services. However, if you prefer not to disclose Personal Information, to the extent permitted by applicable law, you will not be able to register and/or enjoy certain features of our Services. We use Personal Information we collect through the Services for the purposes described in this Policy. For example, we may use personal and other information we collect:

Email newsletters: If you chose to receive promotional email newsletters from Ubisoft when you created your Account, Ubisoft may use the submitted information to send you advertising or promotional materials, including information about special rebates, promotional offers and other events of interest in accordance with your choices. We also use your Personal Information for our internal marketing and demographic studies, so we can constantly improve the products and Services we provide you and to better meet your needs. Additionally, Ubisoft may use your Personal Information outside of its Services to provide you with products, services or advertisements we believe may be of interest to you.

At any time, if you no longer wish to receive promotional e-mails from Ubisoft, please follow one of these two options: (1) when you receive an e-mail from us, it will contain a link or other instruction that allows you to stop the delivery of such messages from us; or (2) contact us at support@ubisoft.com or privacy@ubisoft.com with your request.

If you decide to opt-out of receiving promotional e-mails, you will no longer receive special offers, valuable coupons, new product introductions or e-newsletters from Ubisoft. However, you will continue to receive non-promotional communications from us, such as order confirmations and/or important notifications about the Services and or your Account(s).

Public Profile: Uplay.com and other brand specific Ubisoft sites may offer a public profile feature (“Public Profile”) that allows you to publish information, including Personal Information, to the public Internet. Other than as stated on the applicable public profile site, the information you upload or input to your Public Profile will default to the privacy level you choose at sign-in, and you can choose to change the privacy settings at any time. Those aspects of the Public Profile that are designated as “public” will be visible by everyone, including people off the Ubisoft environment, and may be indexed and displayed through public search engines when someone searches for you. If you post your Personal Information to a Public Profile, including a video, image or photo, you should be aware that these may be viewed, collected, copied and/or used by other users without your consent, and there is no expectation of privacy or confidentiality there. We are not responsible for disclosure by other users of your Personal Information, including without limitation, videos, images or photos that you choose to submit to Ubisoft’s sites. Also, please remember that the Personal Information you provide to us as part of your Public Profile may reveal or allow others to identify aspects of your life that you may not choose to state on your Public Profile directly (for example, your picture may reveal your gender).

Friend Finder tools: By using friend finder tools, you acknowledge that use of these tools will help you find your contacts and will also allow your contacts to associate your Uplay account, other Ubisoft accounts if any (and related gaming entitlements, including games played on PC, mobile and console platforms) with your social networking profile and/or email address. Your resulting friends' list, which may be accessible across Ubisoft sites, will be subject to this Policy. Note that the friends that you choose to include on any friends' list may be able to find and/or identify you in the context of different Ubisoft products and Services, and may see the profiles and information you have made visible to them or to everyone. Similarly, Ubisoft may also collect or receive information about you from other Ubisoft users who choose to upload their email and other contacts. This information will be stored by us and used primarily to help you and your friends connect.

Transfer of Personal Information: Please note that your Personal Information may be transferred to the various offices of Ubisoft located in countries outside Canada, including but not limited to in Europe, the United States, Latin America and Asia. The list of these subsidiaries is available online at https://www.ubisoftgroup.com/en-US/about_ubisoft/world_presence/world_presence.aspx. Your Personal Information may be processed by teams working for Ubisoft or one of its subcontractors outside Canada and will be accessible to employees and agents of Ubisoft subsidiaries and/or subcontractors.

4. Does Ubisoft share Personal Information with third parties?

From time to time and in accordance with applicable law, Ubisoft may employ third-party vendors, to collect Personal Information on Ubisoft's behalf for technical purposes. These third parties provide internal support to Ubisoft by operating some of the Services we provide you, including without limitation email services, payment processing within our Services or our online shop, and for online product fulfilment. If we solicit third parties to collect Personal Information on our behalf, we require all such third parties to comply with and adhere to the material terms of this Policy. When requesting these Services, you may be asked to supply your name, date of birth, billing and mailing addresses, email address, credit card number and valid expiration date. Although these third-party vendors, not Ubisoft, collect the Personal Information you provide when requesting such Services, we require them not to share your Personal Information with third parties. Your Personal Information will not be shared with such third parties to be used for marketing purposes without your consent.

From time to time, we are approached by companies and organizations that provide products or Services that we believe may be of interest to you, and we may share your Personal Information with such third parties in accordance with your choices and after we received your consent. This sharing enables us to provide you with information about products and Services, which might interest you. To the extent that our corporate affiliates and/or technical partners have access to your information, they will follow practices that are at least as restrictive as the practices described in this Policy.

We will also use and share your information for the purposes specifically described below:

Custom Content: We may work with trusted marketing partners to bring you more useful and interesting content on our Services and on third party sites and services. We may do this by sharing or matching the Personal Information you have provided us on the Services with the information (which may include Personal Information) you have provided third parties marketing partners. The list of such trusted marketing partners is available at legal.ubi.com/activesharing/.

If you do not want Ubisoft to match your Personal Information with trusted partners in order for us to tailor ads or other custom content for you on our Services and third party sites and services, please do not check the box labelled “Share my information with selected third parties” during your Account creation. If you later decide that you do not want Ubisoft to match your Personal Information with trusted partners to tailor ads or other custom content for you on our Services and/or third party sites, you can uncheck the box next to “Share my information with select third parties” in your Uplay account settings at any time. When you uncheck this box, Ubisoft will no longer share your Personal Information with partners to tailor ads or other custom content for you following the date of your request.

Please note that opting-out from the Custom Content will not change the behaviour of third parties collecting information on the Services. For more information as to how to opt-out of third party collection please go to: https://legal.ubi.com/cookies/.

Console Accounts/ Social Networks : By playing an Ubisoft game through a social network or other third party platform or service, or by connecting to a third party account, network, platform or service via one of our products and/or Services, you are authorizing Ubisoft to (1) collect, store, and use, in accordance with this Policy, any and all information that you agreed that the console manufacturer, social network or other third party platform could provide to Ubisoft based on your settings on your console account, the third party social network or platform and (2) share any and all of your Personal Information with the console manufacturer, social network or other third party platform, through the third party platform’s Application Programming Interface (API). Your agreement to this takes place when you connect with the third party network, platform or service via our products and/or services, and/or when you connect with, "accept" or "allow" (or similar terms) one of our applications through third party platform or service.

Online Events and Promotions: Your participation in online events and promotions may be conditional upon Ubisoft’s collection, use, storage, transmission and public display of statistical data (such as your scores, rankings and achievements) generated through your participation. This statistical data may include your Personal Information.

Business Information: For practical reasons, we treat Personal Information submitted to us in a business capacity different from information we receive in a non-business capacity. Personal Information submitted to us in a business capacity (e.g. resumes) may be shared with third parties as detailed at the time of collection.

Purchase or Sale of Businesses: From time to time, we may purchase a business or sell one or more of our businesses and your Personal Information may be transferred as a part of the purchase or sale. If we purchase a business, the Personal Information received with that business would be treated in accordance with this Policy, if it is practicable and permissible to do so. If we sell a business, we will include provisions in the selling contract requiring the purchaser to treat your Personal Information in the same manner required by this Policy if it is practicable and permissible to do so. The provisions of this paragraph will also apply if we are sold as part of bankruptcy proceedings.

Disclosures required by law and to protect the security and safety of users: We will disclose Personal Information when we believe in good faith that such disclosures (a) are required by law, including, for example, to comply with a court order or subpoena, (b) will help to: enforce this Policy, our Terms of Use; enforce contest, sweepstakes, promotions, and/or game rules, (c) protect your safety or security, including the safety and security of property that belongs to you; and/or, protect the safety and security of Ubisoft, or any third parties. Unless required by law, Ubisoft will not be required to notify you of any such disclosure.

You understand that when you use the Services, any information you post in any interactive areas of the Services, as well as any information you share with individuals through public or private groups or forums, as well as any information you share with individuals through the Services or through social network sites or other social feeds, will be available to other users and in some cases may be publicly available. We recommend you be cautious about giving out Personal Information to others or sharing Personal Information in public or private online forums. Except to the extent required by applicable law, we are not responsible for the actions of third party service providers or other third parties, nor are we responsible for any additional information you provide directly to any third parties. Therefore, we encourage you to become familiar with their privacy practices before disclosing information directly to any such third parties.

5. Does Ubisoft Collect Personal Information from children under 13?

Unless stated specifically to the contrary on the applicable Ubisoft site, Ubisoft’s Services are not intended for children under 13 (“Child” or “Children”) and Ubisoft will not request any Personal Information from Children. Therefore, Ubisoft restricts access to certain Services on age grounds. In certain jurisdictions, for certain Services and functions, Ubisoft may allow a Child to register for certain Services with parental approval.

When Children are permitted to register for a Service with parental approval, we will take additional steps to protect the Children's privacy, including:

More specifically, when a Child registers, (s)he must supply the e-mail address, and/or other contact information of a parent or legal guardian who will be contacted by Ubisoft to ask him/her to confirm, refuse to modify his/her Child’s registration. The parent/legal guardian may be asked to provide additional documentation or perform additional actions as part of the approval process as consistent with applicable law. Ubisoft reserves the right to refuse access to the Service pending confirmation and activation by his/her parent or guardian. Ubisoft reserves the right to ask for written proof of parental consent for any user or potential user of the services suspected to be a Child. Parental consent applies exclusively to the specific service for which it has been granted.

Certain Services are specifically designed for Children and enable Children to create their own free Accounts for which Ubisoft collects their username or other identifier, password, date of birth (or age), photo, video, voice recording, country, zip code or other geo-locational information, and parent or guardian's e-mail address and/or other parent or guardian contact information. Such Services sometimes offer the possibility of paying for a subscription or certain game functions which enable Children to participate in more activities on the Services by making a payment. The subscription services may also allow parents or guardians to manage their Child's Account and create their own player Accounts.

Certain Services enable Children to create personalized avatars which they can use in numerous activities in the services, including mini-games and virtual worlds. Children may also use other functions of the Services such as "Recommend to a friend" to invite a friend to find out about the Services. The "Recommend to a friend" functions enable Children to send their friends a single message inviting them to visit the related service. Ubisoft will collect the first name and e-mail address of your Child (or, failing that, the e-mail address of the parent or guardian) and the e-mail address of his/her friend for the sole purpose of sending a single message. This information is neither stored nor used for any other purpose and we do not reveal your child's e-mail address to the recipient.

Parents may delete their Child's Account or change their Child's privacy settings at any time by sending an e-mail to the administrator of this Policy, who is identified below. The deletion request will be processed within thirty (30) days of the date of which we receive it.

In all cases, use of the Services by Children must take place under the responsibility of their parents or legal guardians and any use of the Services is assumed to have been validated by them. AS FAR AS IS PERMITTED BY APPLICABLE LEGISLATION, UBISOFT DECLINES ANY RESPONSIBILITY REGARDING ANY ACTIVITIES WHICH MAY BE CONDUCTED BY CHILDREN WITHOUT THE PERMISSION OF THEIR PARENTS OR LEGAL GUARDIANS. IF YOU ARE A PARENT OR LEGAL GUARDIAN AND YOU GIVE YOUR PERMISSION FOR YOUR CHILD TO REGISTER FOR ONE OR OTHER OF THE SERVICES, YOU THEREBY AGREE TO THE TERMS RELATING TO USE OF THE SERVICES BY YOUR CHILD.

6. What if I refuse to provide Personal Information?

We don't require Personal Information to access our Services. However, if you prefer not to disclose Personal Information, to the extent permitted by applicable law, you will not be able to register and/or enjoy certain features of our Services. For example, if you do not submit Personal Information when prompted by Ubisoft, your refusal may limit our ability to process your online product registration, Account creation, contest registration, purchase via our online store, or request for technical support.

7. How long does Ubisoft use Personal Information?

Unless a different use/storage period is required by applicable laws and regulations, Ubisoft will use and store your Personal Information for a length of time necessary for the uses explained in this Policy and in accordance with the requirements and restrictions of Article 4.5 of Schedule 1 to the Personal Information Protection and Electronic Documents Act (L.C. 2000, Ch. 5) (the “Act”).

8. How do I access my Personal Information?

You can access and update the contact information you gave us during registration (that is, your e-mail address or any other information that would directly enable us to contact you), by logging in and clicking the Edit Profile section, or contacting us at support @ubisoft.com. You may be required to provide additional information in order for us to verify your request.

In addition, if for any reason you wish to question, view, correct or delete the Personal Information collected about you by Ubisoft, please send an email to support@ubisoft.com , visit http://support.ubi.com or write to Ubisoft at 5505 St-Laurent Blvd., Suite 5000, Montreal, Quebec, H2T 1S6, Canada Attention: Legal Department.

We will be happy to review, update or remove information as appropriate and pursuant to applicable law. However, we may still retain information in our files to resolve disputes, enforce our agreements, due to technical or legal requirements or matters related to security, integrity or operation of our Services.

Your request will be processed within thirty (30) days of the date of which we receive it.

9. What safeguards does Ubisoft use to protect Personal Information?

The security and confidentiality of your Personal Information is extremely important to us. We use robust security measures to protect Personal Information from loss, misuse and alteration. We use industry-standard practices such as encrypted communications, physically secured rooms, firewalls and password protection systems to safeguard the confidentiality of your Personal Information. From time to time, we review our security procedures to consider appropriate new technology and methods. However, please understand that, despite our best efforts, no security measure is perfect or impenetrable. Please note, we will notify users of a data breach pursuant to applicable law.

To protect the confidentiality of Personal Information maintained in your Account, you must keep your password confidential and not disclose it to any other person. You are responsible for all uses of the Services by any person using your password. Please advise us immediately if you believe your password has been misused.

DESPITE OUR EFFORTS TO KEEP YOUR PERSONAL INFORMATION SECURE, NO COMPANY CAN GUARANTEE THE SECURITY AND PRIVACY OF ITS SERVICES, INFORMATION AND OTHER DATA. ACCORDINGLY, UBISOFT DISCLAIMS AND DOES NOT REPRESENT AND WARRANT THAT IT WILL BE ABLE TO MAINTAIN YOUR PRIVACY OR THE SECURITY OF ITS DATA IN REGARD TO YOUR PERSONAL INFORMATION. OUR PRIVACY POLICIES AND PROCEDURES ARE "AS IS" AND UBISOFT MAKES NO REPRESENTATIONS AS TO THE FITNESS FOR A PARTICULAR PURPOSE OR MERCHANTABILITY.

10. Does this Policy apply to other sites linked by the Services?

The Services may contain links to other sites. For instance, purchases of Virtual Currency or Virtual Items for Ubisoft Services may be transacted on a third party processors site. Any Personal Information you provide on linked pages or applications is provided directly to that third party and is subject to that third party's privacy policy. This Policy does not apply to such linked sites, and we are not responsible for the content or privacy and security practices and policies of these websites or any other sites that are linked to or from the Services. We encourage you to learn about their privacy and security practices and policies before providing them with Personal Information.

11. Ubisoft’s Terms of Use:

The terms of this Policy are incorporated into our Terms of Use. Please review our Terms of Use at: legal.ubi.com/termsofuse. All terms in capital used in this Policy have the meaning as those defined in the Terms of Use located at legal.ubi.com/terms of use.

12. How do I ask questions or send comments about this Policy?

Any questions or complaints or comments about this Policy, please contact Ubisoft :

Please be assured that any Personal Information that you provide in communications to the above email and postal mail addresses will not be used to send you promotional materials, unless you request it.

Ubisoft is a licensee of the ESRB's Privacy Certified Program. If you believe that we have not responded to your inquiry or your inquiry has not been satisfactorily addressed, please contact ESRB by email at http://www.esrb.org/privacy/contact.jsp or by post at:

ESRB

Attn.: Privacy Certified Program
317 Madison Avenue, 22nd Floor
New York, NY 10017
privacy@esrb.org

Last Updated: January 12, 2016