Supplemental EEA+ Privacy Statement

Last updated: September 23, 2025

We, MICOHO INC., address this Supplemental EEA+ Privacy Statement to individuals located in the European Economic Area (EEA), United Kingdom (UK) and Switzerland only (collectively, “EEA+”). This document supplements our MICOHO INC. Privacy Policy and describes how we process your personal data when you use or interact with our website, online advertisements and mobile games (collectively, our “Services”). If there are any inconsistencies between the MICOHO INC. Privacy Policy and this Supplemental EEA+ Privacy Statement, this Statement prevails.

If you are located in the EEA, the EU General Data Protection Regulation applies to our processing of your personal data, as well as local data protection laws, as the case may be. If you are located in the UK, the UK General Data Protection Regulation applies to our processing of your personal data. References to the "GDPR" are references to the General Data Protection Regulation as it applies in the country where you are located. If you are located in Switzerland, the Swiss Federal Data Protection Act (the "FDPA") applies to our processing of your personal data, and references to the GDPR below shall be interpreted analogously for the purposes of applying the FDPA.

1. Who is the data controller?

The data controller is:

MICOHO INC.

2. How can you contact our data protection officer?

You may contact our Data Protection Officer at support@micoho.com.

3. What types of personal data do we collect and how do we collect it?

Please see Section 2 of the MICOHO INC. Privacy Policy. We also use cookies on our website and games as described in our Cookie Policy.

4. For what purposes do we process personal data? What lawful bases of processing do we rely on?

The table further below outlines the purposes for which we process personal data and the lawful bases of processing that correspond with each processing purpose. The lawful bases of processing include the following:

The processing is necessary for us to perform a contract with you or take steps at your request prior to entering into a contract per Article 6(1)(b) GDPR ("Contract Performance Legal Basis");
The processing is necessary for us to comply with an applicable legal obligation per Article 6(1)(c) GDPR ("Legal Obligations Legal Basis");
The processing is necessary for us to realize a legitimate interest based on an assessment of that interest and your privacy and other fundamental interests per Article 6(1)(f) GDPR ("Legitimate Interest Legal Basis"); more information on the balancing test is available upon request; or

The processing is performed according to your consent per Article 6(1)(a) GDPR ("Consent Legal Basis"). In these cases, you can withdraw your consent at any time with future effect by using the consent settings on our website or mobile games, or by emailing us at support@micoho.com with a description of what data processing activities of ours you would like to withdraw your consent from.

Purposes of Use or Disclosure	Legal Basis and Legitimate Interest
To enable us to personalise your in-game profile, provide our games (including the social elements of our games, such as team play and competitions), to ensure that your purchases are activated in the games, to provide you with player support if you need it. To provide access to certain areas, functionalities, and features of our Services, including social features and multiplayer competitions. To enable us to optimize our games for you and for the device that you are using, as well as to deliver customized in-game events, offers, and promotions. To verify your identity and entitlement to products or Services when you contact us or access our Services. To help maintain the safety, security, and integrity of our property and Services, technology assets, and business. To personalize our Services, understand our users and their preferences, and enhance user experience and enjoyment using our Services. To respond to your comments and inquiries and provide customer support services. To ensure internal quality control.	Contract Performance Legal Basis if there is a contract between you and us, or you and we are preparing to enter into a contract. Otherwise, Legitimate Interest Legal Basis—namely to optimize and personalize our Services, and to customize your experience, to maintain security of the Services, and to ensure internal quality control.
To manage our organization and its day-to-day operations. To request your participation in our surveys about our organization, organizations we partner with, and the Services. To develop new games and other Services. To enable players to communicate with each other in games or on our social media accounts. To measure interest in our Services. To conduct internal research and analytics.	Legitimate Interest Legal Basis—namely, to operate and optimize our business; improve our Services; administer communities of users; develop new Services; manage our relationships with users; and ensure the security and integrity of our platforms and systems.
To communicate with you regarding Services-related information, including confirmations, technical notices, updates, security alerts, and support and administrative messages. To provide support through our customer service channels when requested.	If we are contractually required to provide such communications or support, Contract Performance Legal Basis. If applicable laws require us to provide such communications or support, Legal Obligations Legal Basis. Otherwise, Legitimate Interest Legal Basis—namely, to manage our relationship with you.
To enable us to comply with laws that apply to us, to prevent fraud, to ensure compliance with our Terms of Service, or, where necessary, to defend, exercise or establish our legal rights, including our rights under our Terms of Service. To comply with contractual and legal obligations and requirements. To activate, verify, and give effect to parental control settings.	If we are contractually required to process your personal data for these purposes, Contract Performance Legal Basis. If applicable laws require us to process your personal data for these purposes, Legal Obligations Legal Basis. Otherwise, Legitimate Interest Legal Basis—namely, to enable us to comply with laws, prevent fraud, enforce contracts, and defend, exercise or establish our legal rights.
To evaluate and enter into a reorganization, restructuring, merger, acquisition, or whole or partial sale or transfer of our business or assets ("Business Transaction").	Legitimate Interest Legal Basis—namely, to engage in a transaction that our management team considers to be advantageous to our business interests. But we will seek your consent if we wish to use your personal data for any new purpose incompatible with those set forth in our Privacy Statements, and if you provide such consent, the Consent Legal Basis applies.
To use or disclose personal data for targeted advertising purposes. To use tracking technologies other than essential technologies. For more information about our use of cookies, please see our Cookie Policy.	We obtain consent before using tracking technologies other than essential technologies on your device and rely on the Consent Legal Basis to collect and process your personal data through cookies to serve targeted advertising at you and measure the performance of our targeted ads. If you provide your consent, we disclose the following categories of personal data to our advertising technology providers (whose names and privacy statements are listed here: • Identifier For Advertisers (IDFA) or Google Advertising ID • IP address • What Services of ours you have used • Date and time of when you used our Services • Inferred interests. We rely on Contract Performance Legal Basis (if we concluded a contract with you) and on Legitimate Interest Legal Basis for the further processing of personal data collected through the use of essential cookies, such as the provision of a functioning website or game.

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