MUNBOU STUDIO LTD.
PRIVACY POLICY

Effective Date: June 16, 2025

This Privacy Policy applies to Munbou Studio Ltd. ("Studio Munbou", "we", "our" or "us") any game, website or service provided by Studio Munbou, including but not limited to the cross-medium, multimedia game currently titled Whispers of Taiji: Ascent of Aeon ("Game" or "WoT"), the websites www.studiomunbou.com and www.whispersoftaiji.com (and all related subdomains) (collectively, "Website"), and any other product or service provided by Studio Munbou (collectively the "Service"), and details how we collect, use, and disclose data about our users, including you.

BY CLICKING "I AGREE" OR SIMILAR CONFIRMATION OR BY USING THE SERVICE YOU ARE AGREEING TO THE TERMS OF THIS PRIVACY POLICY AS APPLICABLE IN YOUR JURISDICTION.

IF YOU ARE USING THE SERVICE ON BEHALF OF AN ORGANIZATION, YOU REPRESENT THAT YOU HAVE THE AUTHORITY TO BIND THE ORGANIZATION TO THIS PRIVACY POLICY AND ARE AGREEING TO THIS PRIVACY POLICY FOR THAT ORGANIZATION. WHERE YOU ARE USING THE SERVICE ON BEHALF OF AN ORGANIZATION, "YOU" AND "YOUR" REFERS TO THE ORGANIZATION.

1. UPDATES

Studio Munbou reserves the right, in its sole discretion, to modify the Privacy Policy at any time (each, an "Update") and shall make Updates available on Studio Munbou's Website. You are deemed to accept Updates by continuing to use the Service. Unless Studio Munbou states otherwise, Updates are automatically effective 30 days after posting on Studio Munbou Website.

2. HOW WE OBTAIN PERSONAL DATA

The Service involves accessing, collecting and processing personal data, which is information about individuals or that can be used to identify them. Subject to legal, contractual and technical requirements, you may choose not to provide Studio Munbou with certain data or request the deletion of certain data, which may impact essential operations of the Service.

In most cases, Studio Munbou is not the personal data controller and only acts as a data processor. In cases where Studio Munbou is the data processor and not the controller, please contact your data controller prior to contacting Studio Munbou, in order to exercise any of your personal data rights.

We obtain the personal data that we collect from you either directly from you or when you use the Service. In certain circumstances, use of the Service may require you to submit personal data in order to create an account to Studio Munbou directly and/or through third party providers, such as Kickstarter, Steam, PlayStation Network, Xbox Games or My Nintendo (each, an "Account"). In general, Studio Munbou does not have access to Account data you provide to third parties except in order to allow access certain aspects of the Service like video games through such third-party Accounts. Your provision of personal data to Studio Munbou is governed by any terms of use we choose to apply, including third-party license agreements and terms of use (collectively, the "Terms"), which, along with this Privacy Policy, you must agree to in order to use the Service. If you have any questions or concerns about the disclosure of your personal data please contact us at your convenience using the contact information found below.

3. PERSONAL DATA WE COLLECT

We collect personal data about you when you access the Service. The following is a description of the personal data that we may collect, use and/or process in connection with the Service:

• user IDs associated with your Account including but not limited to Android identifiers, iOS identifiers, Google account identifiers, Steam IDs, PlayStation Network IDs, Xbox Games IDs, My Nintendo IDs or social media identifiers as well as any associated login credentials such as passwords (which in most cases are collected and controlled by third-parties to which we do not have access) (collectively, "ID Data");
• your payment data, if you make purchases directly with Studio Munbou, including your payment instrument number and the security code associated with your payment instrument ("Payment Data"), all Payment Data is stored by Stripe and you may find their respective privacy policies here: stripe.com/en-ca/privacy;
• your full name, email address, password, shipping information (if applicable) and Kickstarter pledge/order information (if applicable), when you register an Account on and/or with the Service ("Account Data");
• tracking technologies, such as cookies, web beacons and pixels, to collect data about you such as IP addresses, device information and activities on the Service ("Tracking and Cookies Data");
• certain Account Data and/or your email, telephone number, contact preferences and other contact or authentication data, if you choose to provide it when communicating with us, including by consenting to any of Studio Munbou's marketing, promotional or other communications ("Contact Information");
• basic geolocation data, information about your computer, phone, mobile device, web-connected devices, console or other devices used to connect to the Service including but not limited to, operating system information, operations performed on the device, your computer's Internet Protocol address (i.e. IP address), browser type and version, time and date of Service use, and unique identifiers and tokens that may identify you over time and across different websites including unique device identifiers ("Usage Data"); and
• details about the use of certain Game features, such as level progression, world progression, checkpoints reached, Game completion, collectables discovered and achievements met (collectively, "Game Data").

We also collect anonymous data that does not identify you, including but not limited to responses to anonymous feedback requests, metrics and other types of statistical data, which could be derived from use of the Service and analytical data concerning the Service. This anonymous data collection is not combined with personal data at any time and thus has no chance of identifying you at all.

4. PROCESSING OF YOUR PERSONAL AND ANONYMOUS DATA

We process your personal and anonymous data primarily for legitimate business purposes, which include and are limited to:

• displaying and delivering Account and Game content through the Service;
• authenticating users, maintaining and analyzing functionality of the Service, backing up data or testing and researching new features of the Service;
• supporting the security and integrity of the Service and its users including but not limited to detecting and protecting Studio Munbou and other third-parties against error, fraud, piracy, theft and other illegal activity or for contractual, legal, regulatory or audit obligations;
• understanding your needs to improve the quality and reliability of the Service, including but not limited to providing customer support and feedback, analyzing functionality and technical issues, tracking use of the Service and generating reports and data models that we use to improve the Service;
• investigating improper or suspicious activity on or in the Service;
• contacting you by email and other pre-consented forms for various reasons, including but not limited to user feedback and/or service requests (further pursuant to Section 16, we will only contact you for marketing, promotional or other purposes restricted by applicable law if you have previously consented to being contacted for such purposes and have not withdrawn your consent or subsequently opted-out); and
• displaying and delivering the Game and Game content through the Service including tracking your achievements through your Account(s).

We may disclose your personal data to our parent companies, affiliates, subsidiaries, employees, contractors and agents (collectively, "Studio Munbou Parties") for the same purposes described above. We only disclose your personal data to such Studio Munbou Parties where we have taken steps to ensure that such parties are subject to agreements requiring them to comply with applicable privacy laws and maintain confidentiality standards when handling personal data. Additionally, and as permitted by applicable law, we may also disclose your personal data to third-party service providers, some of whom may be located in a foreign jurisdiction and subject to foreign laws. You may opt-out of your sharing of data with certain third-parties but exercising your opt-out right may impact your use of the Service or the Service features available to you. The situations where we disclose your personal data to third-parties include, but are not limited to:

• processing, storing and analyzing your personal data as described above as well as providing and enhancing the Service features;
• tracking certain events on the Service, such as user interactions, Game information, purchases and related events and providing it to third-parties to analyze and assess performance or obligations;
• providing customer support and feedback, analyzing functionality and technical issues, tracking use of the Service and generating reports and data models that we use to improve the Service; and
• responding to a request from law enforcement or a government that has asserted its lawful authority to obtain the data or where Studio Munbou has reasonable grounds to believe the data could be useful in the investigation of unlawful activity, complying with a subpoena or warrant or an order made by a court, person or body with jurisdiction to compel the production of data, complying with court rules regarding the production of records and data, defending our rights and the rights of others or providing information to our legal counsel.

5. THIRD-PARTY SERVICES

The Privacy Policy only applies to personal data that Studio Munbou collects, processes and discloses and does not apply to the collection, processing and disclosure of data by third parties, through third-party services, which may be broader than set forth in this Privacy Policy, and that may be embedded into and/or part of the Service. In many cases, third-parties may collect personal information about a user's online activities over time and across different websites and services. We strongly recommend that you read each third-party privacy policy carefully before using the Service. Studio Munbou may provide data to third-parties, and/or third-parties may collect data in your use of the Service, including but not limited to: Kickstarter, PBC, Valve Corporation, Sony Group Corporation, Microsoft Corporation, Nintendo Co., Ltd., Google LLC, beehiiv, Inc, Stripe, Inc. and Vercel Inc. Please contact us directly using the information found below if you would like to learn more about third-party data practices.

Specifically for website analytics, we use Vercel Web Analytics. This service helps us understand website traffic and usage by collecting anonymous, aggregated data. Vercel Web Analytics does not use cookies and does not store personal identifiers that could track you across different websites. The data collected includes the page visited, referrer, country, device type, and browser, none of which can be used to personally identify an individual user. While Vercel is one of our data processors for analytics, we configure it to protect your privacy.

6. COOKIES AND DIGITAL TRACKING TECHNOLOGIES

The Service uses Tracking and Cookies Data. Using such data, third-parties may be able to resolve your identity across multiple devices, for example, by matching your IP address, in order to target you based on your online behavior. This data is collected, used and disclosed in accordance with the terms of this Privacy Policy and the applicable third-party privacy policies. Certain features of the Service may rely on tracking technologies and by declining to accept cookies or by changing certain settings on your device, you may not have access to these features. You have the right to opt-in and opt-out of certain cookies that are not necessary for the operations of the Service, including third-party cookies and may do so directly on our Website.

7. OBTAINING, RECTIFYING AND CONTROLLING YOUR PERSONAL DATA

You may contact Studio Munbou to obtain a copy of any personal data we have collected about you, the production of which may be subject to a fee as permitted by applicable law. In addition, you may contact Studio Munbou to correct inaccurate personal data or to complete incomplete personal data.

You may be able to opt-out of some or all of the ways in which your personal data is processed, or request the deletion of certain personal data, except where the personal data is necessary or vital:

• for the performance of Studio Munbou's contractual obligations, such as the Terms;
• to comply with our legal obligations;
• to protect your interests or those of another person; and
• for our legitimate interests or the legitimate interests of a third-party,

and may do so by removing personal data, if the Service permits such removal, by deleting your Studio Munbou Account or by contacting us using the contact information found below.

8. DATA STORAGE, RETENTION AND TRANSFERS

While Studio Munbou is a Canadian company, the data you provide through the Service may be stored and processed by third parties in countries around the world. You authorize Studio Munbou and third parties acting on our behalf to process your data in any country of their choosing, which may cause your data, including personal and anonymous data, to be subject to privacy protections and legal rights that may not be equivalent to those in your country.

Studio Munbou complies with international personal data transfer laws in applicable jurisdictions. For residents in the European Economic Area ("EEA"), Studio Munbou complies with Articles 44-49 of the European Union's General Data Protection Regulation ("GDPR"). Currently, all transfers of personal data to Canada from residents of the EEA are covered by an adequacy decision as described in Article 45 of the GDPR.

Your personal data is retained until you request its deletion or until Studio Munbou no longer requires such data for the purpose for which it was collected or until required to be deleted by laws applicable in your jurisdiction.

9. CHILDREN

Studio Munbou complies with the United States Children's Online Privacy Protection Act and all other applicable laws and regulations concerning children and the Internet. The Service is not directed to and should not be used by children under the age of 13. If we learn that we inadvertently collected personal information from a child under the age of 13 without first obtaining verifiable parental consent, we will delete that information as quickly as possible. If you are a parent or guardian of a child who you believe provided Studio Munbou with personal information without your consent, please contact us at customercare@studiomunbou.com.

If you are a resident of the EEA below the age of consent in your country, Studio Munbou shall comply with applicable consent gathering standards required in your jurisdiction.

10. DO NOT TRACK DISCLOSURE

Do Not Track ("DNT") is a web or device setting that allows users to request that receivers of personal data stop their tracking activities. When you choose to turn on the DNT setting in your browser or device or use alternative consumer choice mechanisms, your browser or device sends a special signal to websites, analytics companies, advertising networks, plug in providers and other web services you encounter to stop tracking your activity. Currently, there are no DNT technology standards and it is possible that there may never be any DNT technology standards. As a result, we do not respond to DNT requests.

11. CALIFORNIA USERS AND "SHINE THE LIGHT" RIGHT

Studio Munbou does not sell any of your personal data to third parties.

If you are a California resident, California Civil Code 1798.83 grants you the right to request our disclosure of the categories of personal information we provided to third parties, and the names and addresses of these third parties, for direct marketing purposes during the preceding calendar year. If you are a California resident and would like to make this request, please contact us using the contact information set forth below. Please note that you may only make this request once per year.

12. LEGAL BASIS FOR PROCESSING PERSONAL DATA UNDER THE GDPR

If you are a resident of the EEA, or another jurisdiction in which substantially similar laws apply, such as the UK, Studio Munbou's legal basis for collecting and using the personal data as described in this Privacy Policy depends on the type of personal data Studio Munbou collects and the context in which it is collected.

Studio Munbou has a legitimate interest, as described in Article 6(1)(f) of the EU GDPR, in collecting your personal data as described in Section 3 of this Privacy Policy for the purposes described in Section 4 of this Privacy Policy. The categories of personal data Studio Munbou collects and the legal basis for its processing are set out below:

Studio Munbou may also process your Contact Information to contact you with newsletters, marketing or promotional materials and other information that may be of interest to you. Pursuant to GDPR Article 6(1)(a), Studio Munbou will acquire your consent prior to processing Contact Information for these purposes. More information on Contact Information and contact preferences is further detailed under Section 16.

We may also process your personal data for additional reasons as they become apparent to comply with the law, or if it is in Studio Munbou's legitimate interests and not overridden by your privacy rights. Such reasons include but are not limited to protecting the Services and you against illegal activity, inappropriate behavior and actions that violate Studio Munbou's Terms.

13. EUROPEAN USERS AND RIGHTS OF EUROPEAN ECONOMIC AREA RESIDENTS

Studio Munbou has a legitimate interest, as described in Article 6(1)(f) of the GDPR, in collecting your ID Data, Payment Data, Account Data, Tracking and Cookies Data, Contact Information, Usage Data and Game Data for use as described in Section 3 of this Privacy Policy for the purposes described in detail in Section 4 of this Privacy Policy. In some cases, the processing of your personal data is also necessary for our provision of the Service to you, such as when we collect personal data from third-parties, as described in Article 6(1)(b) of the GDPR, and such necessary processing supersedes any legitimate interest processing. In other cases, such as when you provide consent to contact you using your Contact Information, Studio Munbou may contact you pursuant to Article 6(1)(a) of the GDPR which supersedes any legitimate interest processing.

If you are a resident of the EEA, you have certain rights in regards to your personal data. These rights include:

• A Right of Access. You have the right to access your personal data that we hold about you free of charge in most circumstances;
• A Right to Rectification. If your personal data is inaccurate or incomplete, you can change the information you provided by changing the information yourself on your Studio Munbou Account or by contacting Studio Munbou using the email listed below;
• A Right to Erasure. You have the right to obtain deletion of personal data concerning you in many cases. In many cases, you may simply delete your information by yourself through your Account but you can also request the deletion by using the contact information found below. Please be careful as deletion of your data in this manner is permanent and cannot be restored;
• A Right to Object. If the processing of your personal data is based on legitimate interests according to Article 6(1)(f) of the GDPR or if your personal data was collected based on your consent, you have the right to object to this processing. If you object we will no longer process your personal data unless there are compelling and prevailing legitimate grounds for the processing as described in Article 21 of the GDPR; in particular if the personal data is necessary for the establishment, exercise or defense of legal claims or if personal data is required for the provision of the Service and you still wish to use the Service;
• A Right to file a Complaint. You have the right to file a complaint with the appropriate supervisory authority in your jurisdiction;
• A Right to Restriction of Processing of your Personal Data. You have the right to obtain restrictions on the processing of your personal data as described in Article 18 of the GDPR;
• A Right to Personal Data Portability. You have the right to receive your Personal Data in a structured, commonly used and machine-readable format and have the right to transmit such data to another controller under the conditions described in Article 20 of the GDPR;
• A Right to Post-Mortem Control of Your Personal Data. If data protection legislation in France is applicable to you, you have the right to establish guidelines for the preservation, the deletion and the transmission of your personal data after your death in accordance with Article 40-1 of the Act No. 78-17 of January 6, 1978 on Information, Technology, Data Files and Civil Liberties; and
• A Right to Opt-out of Marketing Communications. You have the right to opt-out of marketing communications we send you at any time. You can exercise this right by clicking on the "unsubscribe" or "opt-out" link on any marketing e-mails Studio Munbou sends you. To opt-out of other forms of marketing, please contact us using the contact details provided below.

14. CHANGE OF OWNERSHIP OR BUSINESS TRANSITION

In the event of, or in preparation for, a change of ownership or control of Studio Munbou or a business transition such as the sale of Studio Munbou or the sale of some or all Studio Munbou's assets, we may disclose and/or transfer your personal and anonymous data to third-parties who will have the right to continue to collect and use such data in the manner set forth in this Privacy Policy.

15. SECURITY

We are committed to ensuring that your data is secure. To prevent unauthorized access, disclosure, or breach, we have put in place suitable physical, electronic, and administrative procedures to safeguard and secure the data we collect and process.

16. CONTACT PREFERENCES

We communicate with our users primarily through the Service itself and our online forums such as Discord, Reddit, and other various social media, but we may sometimes collect the email address of some of our users in order to respond to support requests or comments. You may also opt-in to receiving our newsletter via your email by consenting on the Website. If you have provided us with your email address and would like to change the email preferences we associate with you (for example, unsubscribing from receiving certain types of email) you may do so by clicking a link within certain types of emails that we send to you or, if no link is available, by replying with "unsubscribe" in the email title or body or by modifying your email settings within the Service. On rare occasions, some types of email are necessary for the Service and cannot be unsubscribed from if you continue to use the Service.

17. CONTACT US

If you have requests, questions or comments about the Privacy Policy or our data collection in general, please contact our Data Protection Officer at privacy@studiomunbou.com