1. INTRODUCTION

    Game Truck understands that the trust of our customers, partners, and employees is our most valuable asset. As a Personal Data Controller, we have an undeniable responsibility to protect the information entrusted to us.

    In a world where data is essential for innovation, security and privacy are not merely details, but fundamental pillars of our operations. In the context of mobile applications, this responsibility is even greater, considering the intimate and personal nature of the data collected through mobile devices.

    This Policy reflects our commitment to ensuring data protection throughout all our activities. It was prepared to serve as a clear and transparent guide, explaining how we process and protect your personal data with the highest degree of technical and ethical rigor, always in compliance with the Brazilian General Data Protection Law (Lei Geral de Proteção de Dados – LGPD).

    PURPOSE

    The main purposes of this Privacy Policy are:

    Transparency and Awareness: To clearly and accessibly explain the conditions under which we process and protect your personal data. We want you to understand exactly what data we collect, why we collect it, and how it is used to improve our services.

    Guarantee of Rights: To describe your rights as a data subject under the LGPD and explain how you may exercise them. Our goal is to facilitate communication so that you can ask questions or request any action related to the protection of your data.

    The guidelines set forth in this Policy apply to all Users and/or Visitors who interact with our Digital Channels, including our website (https://gametruck.app/) and our mobile applications for iOS and Android devices, ensuring that privacy remains a priority across all our platforms.

    SOURCE OF PERSONAL DATA

    GAME TRUCK collects and processes your Personal Data, which may be provided:

    I – by the company that hires GAME TRUCK’s services for your benefit;

    II – through the collection of information from other reliable sources; and

    III – through direct interaction with our mobile applications for iOS and Android, including data automatically collected by the device.

    The information collected by GAME TRUCK includes:

    a) For individuals: name, Brazilian Individual Taxpayer Registry number (CPF), identity card number (RG), email address, marital status, telephone and mobile phone numbers, address, and date of birth;

    b) For legal entities: corporate name, Brazilian National Registry of Legal Entities number (CNPJ), name of the legal representative, identity card number (RG) and Brazilian Individual Taxpayer Registry number (CPF) of the legal representative, number of employees, revenue, full address, and telephone number;

    c) Specific data collected through mobile applications:

    ● Unique device identifiers, including IMEI, advertising ID, and push notification token;

    ● Location information, including GPS data, IP address, and network data;

    ● Application usage data, including session duration, features used, and interactions;

    ● Technical device information, including device model, operating system, application version, and settings;

    ● Connectivity data, including mobile carrier, connection type, and signal quality;

    ● Camera and microphone information, when authorized by the user;

    ● Contacts and calendar information, when authorized by the user;

    ● Biometric data, when available and authorized;

    ● Push notification and communication preferences.

    PURPOSES FOR WHICH WE USE PERSONAL DATA

    At GAME TRUCK, the collection of your personal data is a fundamental and intentional process guided by the purpose limitation principle. We collect and use your information to ensure that our services not only meet but exceed your expectations, operating in a secure, reliable, and, above all, useful manner.

    The data entrusted to us has a clear purpose. It enables us to:

    Provide Our Services: We use your information to manage and fulfill all obligations related to the services we provide, ensuring a smooth and uninterrupted experience.

    Improve Your Experience: Through the use of data, we identify opportunities to improve our products and services, creating more efficient solutions aligned with your needs.

    Keep You Informed: We use your data to keep you updated about news, features, promotions, and other events that may be of interest to you, always with the goal of adding value to our relationship.

    Ensure Security: Data helps us strengthen the security of our services and prevent fraud, protecting both you and the integrity of our platform.

    Comply with Our Legal Obligations: In specific circumstances, we may use your data to cooperate with authorities or comply with court orders, always in strict accordance with applicable law.

    Specific purposes related to mobile applications include:

    ● Personalizing the user experience;

    ● Geolocating services;

    ● Optimizing performance;

    ● Providing personalized notifications;

    ● Conducting usage analysis;

    ● Providing technical support;

    ● Conducting targeted marketing;

    ● Synchronizing data across devices.

    It is important to emphasize that GAME TRUCK does not sell or otherwise commercially exploit your personal data. Your privacy is our priority, and your information is handled with the highest level of care and confidentiality. Should any additional purpose for the use of your data arise, you will be informed transparently and clearly at the time of collection.

    LEGAL BASIS FOR THE PROCESSING OF PERSONAL DATA

    GAME TRUCK processes Personal Data as part of the performance and management of our contractual relationship with you and/or with the company that hires our services; based on our legitimate interests or those of third parties, provided that the applicable legal requirements are met; in compliance with certain legal or regulatory obligations; or when necessary for the regular exercise of rights in judicial, administrative, or arbitration proceedings.

    Your Personal Data may also be processed based on your prior consent when, under certain circumstances, your consent is requested.

    SHARING OF PERSONAL DATA

    The security and confidentiality of your Personal Data are extremely important to us. Therefore, we restrict access to your Personal Data exclusively to our duly authorized professionals who need access to such data in order to process your requests or provide the requested service.

    We will not disclose your Personal Data to unauthorized third parties. However, we may share your Personal Data with entities within the client’s corporate group and with authorized service providers with whom we work, such as call centers, customer relationship agents, back-office service providers, technology and information technology consultants, cloud infrastructure providers, analytics services, push notification platforms, and third-party software development kits integrated into our applications. We may engage these parties for the purpose of providing our services.

    Specific sharing in the context of mobile applications may include:

    ● Application stores;

    ● Cloud service providers;

    ● Analytics services;

    ● Notification platforms;

    ● Third-party software development kits;

    ● Technology partners.

    In such cases, we ensure that your Personal Data is processed only for legitimate, specific, explicit purposes that have been disclosed to you, without the possibility of further processing in a manner incompatible with the stated purpose.

    In addition, we may share Personal Data relating to you when we believe, in good faith, that we are required to:

    I – comply with a law, regulation, or court order;

    II – respond to requests for information made by regulatory bodies, law enforcement authorities, and other public authorities, including requests relating to national security;

    III – enforce and/or protect GAME TRUCK’s property or rights, including investigating fraud and helping prevent security threats, including information security threats, or other criminal or malicious activities; or

    IV – protect the legitimate interests of third parties, including the personal safety of GAME TRUCK employees.

    STORAGE OF YOUR PERSONAL DATA

    We store your Personal Data in our databases within a secure environment, ensuring its secrecy and confidentiality, only for as long as necessary to fulfill the purposes for which it was collected, subject to any applicable legal retention periods and GAME TRUCK’s need to defend itself in legal proceedings.

    However, in certain circumstances, we may be required to retain your Personal Data for a longer period due to applicable laws or regulations. Once the applicable retention period and legal necessity have ended, your Personal Data will be deleted using secure disposal methods or anonymized for statistical purposes.

    For data collected through mobile applications:

    ● Local cache data is temporarily stored on the device for performance optimization;

    ● Synchronized data is stored on secure servers using encryption both in transit and at rest;

    ● Security logs are retained for the period necessary to investigate incidents;

    ● Automated backups are performed at a frequency determined by technical and legal requirements.

    However, in certain circumstances, we may be required to retain your Personal Data for a longer period due to applicable laws or regulations. Once the applicable retention period and legal necessity have ended, your Personal Data will be deleted using secure disposal methods or anonymized for statistical purposes.

    Users may manage locally stored data through the application settings, including clearing cache and offline data.

    SENSITIVE PERSONAL DATA AND DATA RELATING TO CHILDREN AND ADOLESCENTS

    Should it be strictly necessary to collect such data in order to achieve the purpose for which the processing is performed, we will do so in accordance with applicable local legal requirements regarding the protection of Personal Data and, in particular, based on your prior, specific, and clearly highlighted consent for specific purposes under the conditions described in this Policy.

    Additional protections applicable to mobile applications include:

    ● Biometric data, including fingerprints and facial recognition data, is processed locally on the device whenever possible;

    ● Precise location data requires explicit consent and may be disabled through the device or application settings;

    ● For minors, we require parental or legal guardian consent whenever applicable and implement specific protection controls;

    ● Health data or data relating to personal characteristics collected through device sensors is subject to special processing requirements under the LGPD.

    INTERNATIONAL TRANSFER OF PERSONAL DATA

    Because GAME TRUCK’s area of operation is aligned with the area of operation of its CLIENTS, your Personal Data may, in certain circumstances, be transferred to recipients located outside Brazil who are authorized to provide services on our behalf.

    In the event of an international transfer to recipients located in other countries, we will adopt the necessary measures to ensure the existence of appropriate safeguards for the protection of your Personal Data in accordance with the LGPD and the protections described in this Policy.

    In the context of mobile applications, international transfers may occur involving:

    ● Global content delivery network servers used for performance optimization;

    ● Data centers operated by cloud service providers and located in different regions;

    ● Third-party services integrated with international infrastructure;

    ● Application stores operated by Apple and Google, which conduct global operations.

    In the event of an international transfer to recipients located in other countries, we will adopt the necessary measures to ensure the existence of appropriate safeguards for the protection of your Personal Data in accordance with the LGPD and the protections described in this Policy, including standard contractual clauses, adequacy certifications, and other mechanisms recognized by the Brazilian National Data Protection Authority (Autoridade Nacional de Proteção de Dados – ANPD).

    EXERCISE OF YOUR RIGHTS UNDER THE LGPD

    GAME TRUCK respects the rights you hold as a Personal Data subject and enables you to exercise those rights in accordance with Article 18 of Brazilian Law No. 13,709/2018.

    Specific mobile application features for exercising your rights include:

    ● An in-app Privacy Center for managing consent;

    ● Data settings that provide granular control over data collection and processing;

    ● The ability to export data directly through the application in a structured format;

    ● Deletion requests subject to confirmation and an established completion period;

    ● Consent history for reviewing and modifying permissions.

    To exercise any of the rights mentioned above, please refer to Section 14: CONTACT US REGARDING YOUR RIGHTS UNDER THE LGPD.

    To protect your privacy and as a security and fraud-prevention measure, we may request proof of your identity before fulfilling your request.

    SECURITY MEASURES APPLICABLE TO THE PROTECTION OF PERSONAL DATA

    We implement the best available technical and administrative security practices to protect your Personal Data against unauthorized access and accidental or unlawful situations involving destruction, loss, alteration, communication, or disclosure, as required by applicable law.

    Specific security measures applicable to mobile applications include:

    ● End-to-end encryption for sensitive data in transit and at rest;

    ● Multi-factor authentication when available on the device;

    ● SSL/TLS certificates for all communications with servers;

    ● Code obfuscation to protect against reverse engineering;

    ● Jailbreak and root detection with appropriate protective measures;

    ● Real-time monitoring of unauthorized access attempts;

    ● Automatic security updates when available;

    ● Segregation of data according to sensitivity levels;

    ● Encrypted audit logs for incident investigations.

    However, please be aware that no company, including the client, can completely eliminate the security risks associated with the Processing of Personal Data.

    For your own security, it is essential that you protect your password and computer against unauthorized access. Your access credentials are personal and non-transferable, and you are solely and exclusively responsible for their use.

    In the event of any attempted improper or unauthorized access, you must notify GAME TRUCK as soon as possible.

    ACCESS TO AND UPDATES OF OUR PRIVACY POLICY

    By accessing GAME TRUCK’s DIGITAL CHANNELS, you expressly agree to this Policy.

    For your own security, you must read and ensure that you understand all the conditions established in this Policy, as well as in any other documents incorporated into it by reference.

    The mobile applications will request your agreement to this Policy upon first use and whenever material updates are made.

    By accepting the terms of this Policy, you expressly agree to provide only true, current, and accurate Personal Data. You will be solely responsible for any false, outdated, or inaccurate information that you provide directly to GAME TRUCK.

    Should this Policy be amended, we will publish the new version through our DIGITAL CHANNELS. The new version will indicate the date on which the revision was made so that you may remain informed of the updated content.

    For mobile applications:

    ● In-app notifications will inform users of updates to this Policy;

    ● An offline version will always be available within the application;

    ● The version history may be accessed through the application settings;

    ● Renewed consent will be requested whenever necessary.

    All amendments will become effective immediately upon publication of the revised Privacy Policy, unless otherwise specified. Therefore, we recommend that you review this Policy periodically in order to remain informed of any changes.

    The date of the most recent update to this Policy is indicated at the end of this document and reflects the effective date of this Policy. Previous versions of this Policy may be requested through the email address indicated herein.

    APPLICABLE LAW AND JURISDICTION

    This Privacy Policy is governed by and interpreted in accordance with Brazilian law, with particular emphasis on the Brazilian General Data Protection Law (LGPD). For mobile applications, the applicable application store guidelines, including the Apple App Store Guidelines and Google Play Policies, will also apply when compatible with Brazilian law.

    To resolve any dispute or controversy arising from this document, the parties elect the courts of the Judicial District of Campo Grande as having jurisdiction. This choice does not exclude any specific personal, territorial, or subject-matter jurisdiction established by law.

    In addition, in order to promote the more amicable and efficient resolution of disputes, matters involving data subjects may be referred to JUSPRO – Justiça Sem Processo Mediação e Conciliação S/S Ltda., acting as a Mediation Chamber pursuant to Article 52, Paragraph 7, of the LGPD. This approach is intended to promote constructive dialogue and the resolution of matters without the need for judicial proceedings.

    CONTACT US REGARDING YOUR RIGHTS UNDER THE LGPD

    GAME TRUCK is pleased to announce the appointment of Mr. Eduardo Paiva and Ms. Jéssica Rodrigues as our Data Protection Officers (DPOs). This decision reinforces our commitment to ensuring the security and privacy of your personal data.

    The DPOs will oversee all new data protection practices to be adopted within our corporate group beginning on October 1, 2025, leading our journey toward compliance and excellence.

    Should you have any questions or require information regarding the processing of your personal data, you may contact the DPOs directly through the following channels:

    ● Telephone: +55 (24) 92006-6141 / +55 (47) 93300-9607

    ● Email: lgpd@gametruck.app

    ● In-app form: Available in the “Privacy” section of the mobile applications.