Our Use of CCTV

We have installed CCTV cameras in various areas of our premises for the following purposes:

• To protect our facilities, assets, and personnel; and

• To deter, detect, record, and allow analysis of any type of incident, including malicious actions such as theft or vandalism, accidents, fires, floods, and other emergency situations.

We recognise the need to balance an individual's right to privacy with the need to ensure the safety and security of the Company’s employees, visitors, and corporate assets. We do not deploy CCTV equipment in private areas, such as private rooms, toilets or changing rooms.

Where CCTV is deployed externally, we try to avoid capturing images of public streets and buildings (including private spaces) which do not belong to the Company (unless permitted by local law).

Notice of CCTV filming will be provided through appropriate signage placed in a prominent location and as close to the camera as possible. Unless we can demonstrate it is otherwise justified under applicable law, we will not deploy covert CCTV technology.

Our CCTV systems respond to motion and are always active. Our Physical Security teams have access to the feed as well as the recordings from the cameras. The Company does not exercise automated decision-making, including profiling during the operation of CCTV.

Why We Collect, Use, and Store this Personal Data

We deploy CCTV for the purposes listed above. We do so based on our legitimate interests based on the data protection rules of your jurisdiction in maintaining the security of persons and integrity of our facilities and for use in connection with legal claims, compliance, regulatory, auditing, insurance, investigative, and disciplinary purposes and other ethics and compliance reporting requirements as permitted by local law.

We may also process your personal data contained within CCTV footage where necessary to comply with a legal obligation, such as disclosures to law enforcement agencies or in connection with legal claims, health & safety compliance, regulatory, investigative, and disciplinary purposes (including disclosure of such information in connection with legal process or litigation).

How Long We Retain CCTV Footage

As a matter of course, and depending on the location (see below), we retain the footage we collect for no longer than the time period identified below, after which any collected footage is overwritten and deleted.

We only retain copies of select portions of footage for longer periods in specific circumstances where there is a specific and justified reason to do so, including for investigative or legal purposes. We retain such copies only for as long as needed for the identified purpose and a reasonable period thereafter to defend against ongoing, reasonably anticipated, or potential legal claims.

How We Collect Your Personal Data

Your personal data shall be collected in electronic form via CCTV devices.

How We Share Your Personal Data

Only authorised personnel have permission to operate the CCTV systems and view the images, including our Company Physical Security Team, and appropriate management (e.g., facility manager), internal and external legal advisors, insurance providers, and police, law, and regulatory enforcement authorities.

The data is stored locally and may be transferred to a destination outside of your jurisdiction. Due to the global nature of our business, your personal data will be disclosed to Take-Two entities in the United States.

Where these locations do not provide an adequate level of data protection as assessed by the relevant authority, we ensure appropriate safeguards are in place to protect the transfer of your personal data to these countries. We primarily use standard contractual clauses applicable in your jurisdiction. A copy of the relevant mechanism can be obtained for your review on request by using the contact details below.

Your Choices and Rights

With regard to your personal data that we process, you may have the following rights: You have the right to ask the Company for a copy of your personal data; to correct, delete or restrict processing of your personal data. In addition, you can object to the processing of your personal data in some circumstances (in particular, where we don’t have to process the data to meet a contractual or other legal requirement or compelling interest).

In France you have the right to leave guidelines about the processing of your personal data after your death.

In Hungary your relatives or someone you authorise may exercise your data subject rights on your behalf after your death, you can lodge a complaint before a Tribunal competent based on the Company’s registered seat or your place of residence, and the viewing angles of cameras in Hungary are indicated on a floorplan available on request.

These rights may be limited, for example if fulfilling your request would reveal personal data about another person, or if you ask us to delete information which we are required by law or have compelling legitimate interests to keep. Relevant exemptions are included in the data protection laws of your jurisdiction. We will inform you of relevant exemptions we rely upon when responding to any request you make.

To exercise any of these rights, you can get in touch with us using the details set out below. If you believe that we have not complied with the requirements of data protection laws of your jurisdiction with regard to your personal data, you have the right to lodge a complaint with the data protection authority in the country where you live, work, or where you believe a breach may have occurred. Information on these authorities is included in the table below.

Contact Us

The data controller for the data we process will depend on the location you are in and is set out in the table below. If you contact us and wish to exercise your rights under the data protection laws of your jurisdiction as detailed above, please identify the controller and CCTV location where your data was captured. Also please tell us if you are a visitor or an employee of the controller in that location.

If you have questions about this policy or wish to contact us for any reason in relation to our personal data processing, please contact us at [email protected].