GameLoot Privacy Policy

Last Updated: July 10, 2026

1. INTRODUCTION

Welcome to GameLoot ("Marketplace", "we", "our", or "us").

Your privacy is important to us. This Privacy Policy explains how we collect, use, disclose, store and otherwise process your personal data when you access or use our Alternative App Marketplace, website, mobile applications, developer portal and any related services (collectively, the "Services").

We are committed to processing personal data in accordance with:

lRegulation (EU) 2016/679 (General Data Protection Regulation, "GDPR");

lapplicable national data protection laws within the European Economic Area ("EEA");

• the Digital Services Act ("DSA"), where applicable;
• other applicable privacy and consumer protection laws.

This Privacy Policy describes: what personal data we collect; how we process personal data; why we process personal data; how we protect personal data; your rights regarding your personal data.

Please read this entire Policy carefully and any other agreements that apply to your use of the Services, and confirm you understand and agree to them, before using any of the Services. If you have any questions, you can always reach out to us using the contact information listed in Section 15.

2. SCOPE OF THIS PRIVACY POLICY

This Privacy Policy applies to personal data processed by us in connection with: accessing and using our Marketplace; browsing available applications; searching for applications; downloading and installing applications; updating applications; managing Marketplace accounts; contacting customer support; security monitoring; compliance activities.

This Privacy Policy applies to: end users accessing the Marketplace; visitors to our websites; individuals communicating with us regarding the Services.

This Privacy Policy does not apply to: Apple's processing of personal data through iOS, Apple ID, App Store services or other Apple services; processing activities conducted independently by third-party application providers; third-party websites, services or applications that are not operated by us.

Where third-party applications or services are accessed through the Marketplace, those third parties may have their own privacy policies governing their processing activities.

3. RELATIONSHIP WITH APPLE

The Marketplace operates within the technical and regulatory environment established by Apple for alternative application distribution on iOS.

Apple independently processes personal data relating to its own services, including where applicable: Apple Account services; iOS operating system functions; device security mechanisms;

payment services; Apple's own authentication and security processes. Apple determines the purposes and means of its own processing activities and acts as an independent controller for such processing.

This Privacy Policy does not replace or modify Apple's privacy documentation. You should review Apple's privacy information regarding Apple's processing activities.

4. RELATIONSHIP WITH THIRD-PARTY APPLICATION PROVIDERS

Applications available through the Marketplace may be provided by independent third parties.

Those third parties may independently determine: whether and how they collect personal data;

the purposes of their processing; the technologies used within their applications; their retention periods and security measures. Unless expressly stated otherwise, we do not determine the purposes or means of personal data processing carried out within third-party applications. Users should review the privacy notices provided by application providers before downloading or using applications.

5. OVERVIEW OF PERSONAL DATA WE COLLECT

The categories of personal data we collect depend on how you interact with the Services and the features you choose to use. We apply the principle of data minimisation and collect only personal data that is reasonably necessary for: providing the Marketplace; enabling application discovery, download and installation; maintaining platform security; improving service reliability; complying with applicable legal obligations.

The categories of personal data we may process include: account information; device and technical information; Marketplace usage information; application installation information; communication information; security and diagnostic information; information necessary for legal and regulatory compliance.

A. Account Registration Information

Where account creation is required to access certain Marketplace features, we may collect information such as:

• email address;
• username or account identifier;
• password credentials stored in encrypted form;
• account preferences;
• language preference;
• country or region settings.

We use this information to:

• create and manage your account;
• authenticate your access;
• provide account-related services;
• communicate important service information.

B. Customer Support Information

When you contact us for support, we may collect:

• your name or account identifier;
• email address;
• communications with our support team;
• screenshots or files voluntarily submitted by you;
• technical information necessary to investigate your request.

We process such information solely for:

• responding to enquiries;
• resolving technical issues;
• improving customer support;
• maintaining records of support activities.

lWe do not require users to provide information that is not necessary for providing the Services.

C. Feedback and Reports

Where you voluntarily provide feedback, reviews, reports or other communications, we may process:

• the content of your submission;
• associated account information;
• supporting materials provided by you.

Such information may be used to:

• improve the Services;
• investigate reported issues;
• maintain platform integrity.

D. Device and Technical Information

When you access or use the Marketplace, we may automatically collect certain technical information necessary for operation, security and reliability. Such information may include:

• device model;
• device manufacturer;
• operating system version;
• iOS version;
• Marketplace application version;
• device language;
• device region;
• time zone;
• network information;
• IP address;
• technical identifiers generated for service operation;
• error logs;
• crash reports;
• performance information.

We use this information to:

• ensure compatibility between the Marketplace and your device;
• maintain service availability;
• diagnose technical problems;
• prevent security incidents;
• improve system performance.

E. IP Address and Network Information

When you access the Services, our systems may automatically process your IP address and related network information.

IP address information may be used for:

• establishing a secure connection;
• detecting abnormal activity;
• preventing fraud and abuse;
• maintaining system security;
• generating aggregated technical statistics;
• complying with legal obligations.

Where required by applicable law, we apply appropriate safeguards to limit the use and retention of IP address information.

F. Application Discovery, Download and Installation Information

To provide Marketplace functionality, we may process information relating to your interaction with applications available through the Marketplace.Such information may include:

• applications viewed;
• application searches;
• download requests;
• download status;
• installation status;
• update status;
• application version information.

This information is used to:

• provide requested downloads;
• enable application updates;
• maintain Marketplace functionality;
• troubleshoot technical issues;
• protect against misuse.

We do not use application installation information to access the content or personal data stored within third-party applications.

G. Security and Fraud Prevention Information

We may process technical information necessary to protect the Marketplace, users and third parties.Such information may include:

• login activity;
• authentication events;
• security alerts;
• abnormal usage patterns;
• suspected abuse indicators;
• technical logs.

We process this information to:

• detect malicious activity;
• prevent unauthorised access;
• protect Marketplace infrastructure;
• investigate security incidents;
• enforce applicable policies.

Where possible, we use aggregated, anonymised or pseudonymised information for security analysis.

H. Communication Information

If you communicate with us, we may process:

• email correspondence;
• customer service records;
• complaint information;
• dispute-related communications;
• documents voluntarily provided by you.

We process communication information to:

• respond to requests;
• provide support;
• maintain service records;
• resolve disputes;
• comply with legal obligations.

I. Information Collected Through Cookies and Similar Technologies

Our websites and certain online services may use cookies and similar technologies.

Such technologies may collect:

• browser information;
• session information;
• preference settings;
• usage statistics;
• security-related information.

The use of cookies and similar technologies is described further in our Cookie Policy.

Where required by applicable law, we obtain consent before using non-essential cookies or similar technologies.

6. INFORMATION WE DO NOT INTENTIONALLY COLLECT

To protect user privacy and comply with data minimisation principles, we do not intentionally collect certain categories of information unless required for a specific lawful purpose.

Such information may include:

lthe content of personal files stored within downloaded applications;

• messages exchanged within third-party applications;

lpayment card details processed by Apple or independent payment providers;

• Apple Account passwords;
• biometric information;

lprecise location information, unless specifically required and separately disclosed;

• information unrelated to providing or securing the Marketplace.

We do not seek to access personal data contained within third-party applications.

7. CHILDREN'S PRIVACY

We recognise that children are entitled to specific protection under applicable data protection laws. The Services are not intended for individuals who do not meet the minimum age requirements under applicable law. Where the processing of a child's personal data requires parental or legal guardian consent under applicable law, we will take appropriate steps to obtain or verify such consent where required.

We do not knowingly collect personal data from children in violation of applicable law. If we become aware that we have collected personal data from a child without the required legal basis, we will take reasonable steps to delete or otherwise address such personal data without undue delay. Parents or legal guardians who believe that a child has provided personal data to us in violation of applicable law may contact us using the contact details provided in this Privacy Policy.

8. PURPOSE OF PROCESSING

We process the information we collect, either individually or in combination with other information as described in this Policy, for the purposes outlined below.

To provide and operate the Services(contractual necessity or legitimate interests): For example, we may use your information to create and maintain your account, grant you access to the Services, including verifying your identity, enable features of the Services, and manage your transactions, save your preferences, enforce our terms and policies, notify you about changes to our terms and policies, and contact you about your account, transactions, and other service-related messages necessary for the operation of the Services.

To support and monitor the Services(legitimate interests or contractual necessity): For example, we may use your information to respond to support requests and general inquiries sent by you, and detect and report crashes.

To secure and protect the Services and others(legitimate interests, contractual necessity, or legal obligations): For example, we may use your information to detect and prevent fraud, cheating, hacking, account theft, misuse, and other unauthorized activities on the Services, and protect the rights, property, and safety of , our users, and others.

To moderate the Services(legitimate interests, legal obligations, or contractual necessity): For example, we may use your information to detect, moderate, and respond to reported illegal, harmful, toxic, and fraudulent content and conduct that violates applicable laws or our terms and policies.

To develop the Services(legitimate interests): For example, we may use your information to early access tests and gather feedback.

To understand and improve the Services(legitimate interests): For example, we may use your information to analyze your use of the Services, support auditing, and improve features, technologies, and processes, including detect and moderate illegal, harmful, toxic, and fraudulent conduct and content that violates applicable laws or our terms and policies.

To personalize the Services(consent or legitimate interests): For example, we may use your information to present content, features, and recommendations tailored to you, or inferred from your activity.

To establish and defend legal claims(legitimate interests or legal obligations): For example, if you bring a legal claim against us, we may use your information to investigate and respond to that claim and defend ourselves; and where we detect misuse of the Services, we may use your information to establish and pursue our legal claims.

To comply with applicable laws, regulations, and legal processes(legal obligations): For example, we may use your information to respond to valid requests from law enforcement and government authorities, including subpoenas, court orders, and search warrants; and we may use your date of birth to facilitate compliance with youth protection laws.

To purposes you’ve consented to(consent): For example, with your consent, we may use your information to send you marketing communications. You are not required to provide your consent, and you may withdraw your consent at any time.

We may also process your information for additional purposes in the future, compatible with those described above, and we may explain the purpose to you at the time of collection.

9. INFORMATION DISCLOSURE

We may disclose some of your information to our subsidiaries and affiliates, our service providers, and third parties for the purposes set forth above.

When we disclose information to our service providers, we endeavor to ensure these service providers provide protections that are the same as, or substantially similar to, those described in this Policy (e.g., by limiting the use of your information to the services provided). Our service providers include: database hosting and storage providers; email service providers; and payment processors.

Depending on the Services you use and how you interact with them, third parties include:

lpublishers of games you buy or play through the Gameloot Store to enable the transaction and product features;

ldevelopers to authenticate you and enable features like friends lists and crossplay if you sign into their games or apps using your account;

lour lawyers, consultants, accountants, business advisors, and similar third parties who owe us duties of confidentiality;

la buyer or other successor in the event of a sale, merger, divestiture, restructuring, reorganization, dissolution, or other transfer of some or all our assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which information retained by us pertaining to users of the Services is among the assets transferred;

llaw enforcement, government authorities, or others as required to comply with applicable laws, regulations, or legal processes, or if we believe disclosure is necessary to protect the rights, property, or safety of Gameloot , our users, or others; and

• others with your permission.

No mobile phone numbers provided to Gameloot for security purposes will be shared with third parties or affiliates for marketing or promotional purposes.

10. WHERE YOUR INFORMATION IS PROCESSED

Oasioneer Interactive Limited is based in Ireland, but we operate to help provide users all around EU with a better experience on the Services. This means that Gameloot may process, store, and transfer your information outside the country where you live.

When we transfer your information outside the country where it was collected, we rely on appropriate legal mechanisms to support the transfer and implement technical, organizational, and physical safeguards to secure your information. These measures include model contractual clauses (such as the European Commission’s Standard Contractual Clauses) and, if applicable, adequacy decisions by regulatory authorities.

Where permitted by law, your use of the Services authorizes us to process your information in any country we operated .

11. DATA PROCESSING

A. Retention

Because the specific information we process and our reasons for doing so often vary depending on how you use the Services, how long we retain your information can also vary. We generally retain information for as long as we reasonably need it for the purposes described in Section 5 (Why Do We Process Information?), unless a longer retention period is required or permitted by law. For example, if you create a Gameloot account, we will generally retain the information associated with your account (e.g., name, public-facing display name, password, country, and email address) for as long as needed to maintain your account, provide the Services you requested, enforce any terms and policies that apply to and govern your use of the Services, and record how we deliver the Services to you.

The main criteria we consider in determining specific retention periods often include minimum requirements under applicable law, relevant industry standards, the types of information in question (e.g., its level of sensitivity), the purposes for which we process the information (e.g., complying with our legal obligations, managing internal records, enforcing our terms and policies, and resolving disputes), whether we can achieve those purposes through other means, the potential risk of harm from unauthorized use or disclosure of the information, the information’s relevance to potential litigation or similar proceedings (e.g., defending ourselves against legal claims), and whether the information is required to prevent fraud or similar abuse of the Services (e.g., enforcing prohibitions against cheating and other unauthorized behavior).

B. Security

We maintain appropriate administrative, technical, contractual, and physical safeguards to secure your information from accidental, unlawful, or unauthorized destruction, loss, alteration, access, disclosure, use, or other unlawful forms of processing. In some cases, your information may be accessible when you use the Services. To help keep your information secure, you must maintain the confidentiality of your login information. If we become aware of unauthorized disclosure of your information, we will notify you as required by law and take appropriate steps to help secure your information.

12. UPDATES TO THIS PRIVACY POLICY

We may update this Privacy Policy periodically to reflect: changes to our Services; changes in applicable laws; regulatory guidance; improvements to privacy practices. Where changes materially affect your rights or the way we process personal data, we will provide appropriate notice as required by applicable law. The effective date shown at the beginning of this Privacy Policy indicates the latest revision date.

13. YOUR RIGHTS

We seek to provide you with meaningful choices about the information we collect. The specific choices available to you often vary depending on the exact nature of our relationship with you, such as the Services you use. Common examples include:

• access your personal data;
• correct your personal data;
• deletion of your personal data;
• temporarily restrict our use of your personal data;

lobject to some types of processing, including processing for direct marketing purposes and based on our legitimate interests;

ldata portability, including receiving a copy of your personal data; and

lwithdraw your consent, where our processing is based on consent (if you withdraw your consent, this does not affect the lawfulness of any processing based on your consent before it was withdrawn).

• You can correct your information through your Gameloot account.

lYou can request that we provide access to, or correct or delete, information we have collected from you.

lYou can change your privacy settings on third-party platforms, websites, and services to limit the information they disclose to us.

lYou can manage cookies and other automatic data collection technologies through your browser or device settings (e.g., by blocking, deleting, or limiting them). Please note that disabling cookies may cause parts of the Services to not work properly and some features may become unavailable.

lIf you’re under the age of 18 and have a Gameloot account, you can request that we remove or anonymize certain content you provided on the Services.

lParents/guardians can adjust settings for their child’s Gameloot account.

To submit a request, please contact us using the contact information listed in Section 15.

We may ask for additional information to verify your identity before fulfilling a rights request. We may also limit our response in certain circumstances, including when:

• the request is manifestly unfounded or excessive;

lthe request would adversely affect the rights and freedoms of others;

lthere are overriding legitimate grounds for processing that overweigh your interests, rights, and freedoms; or

lthe processing is necessary to establish, exercise, or defend our legal claims, perform a contract with you, or comply with our legal obligations.

14. COMPLAINTS AND LEGAL BASE FOR PROCESSING

You have the right to contact us directly with any complaint. We would appreciate the chance to address your issues first.

The lawful bases we rely on to process your personal data depend on the Gameloot Services you use and how you interact with them. These lawful bases are:

lContractual necessity: when we process your personal data to perform the Gameloot Services you requested under our Terms of Service or other similar contractual agreements with you.

lLegitimate interests:when we process your personal data to support Gameloot’s business purposes, as balanced against the potential impact on your privacy rights.

lLegal obligations: when we process your personal data to comply with our legal obligations.

lConsent: when you give us your consent to process your personal data. You are not required to provide consent, and you may withdraw your consent at any time.

15. CONTACT US

If you have questions or concerns about the Gameloot Services (e.g., issues related to a game, accessing your Gameloot account, bugs, payments, content, or entitlements), please contact [email protected].

If you want to learn more about our privacy practices or this Policy, or exercise your data subject rights, please email [email protected].

Contact Information:

Oasioneer Interactive Limited

Address:5th Floor, Nova Atria North, Blackthorn Road, Sandyford Business Park, Sandyford, Dublin 18.

Contact:[email protected]