Supplier Privacy Notice

Your privacy is important to Asmodee. This Privacy Notice explains how we handle and treat your personal data when we do business with you or your company.

This Privacy Notice explains our approach to any personal data that we collect from you or that we have obtained about you from a third party and the purposes for which we process your personal data. It also sets out your rights in respect of our processing of your personal data.

We may collect personal data from you in the course of our business, including when you contact or request information from us, or as a result of your relationship with one or more of our staff or partners.

1. Who is responsible for your personal data?

2. What personal data do we collect about you?

3. How do we use your personal data?

4. Who do we disclose your personal data to?

5. How long do we retain your personal data?

6. Security of your personal data

7. What are your rights?

8. Contact and complaints

9. Changes to this Privacy Notice


1. Who is responsible for your personal data?

Asmodee Group, with registered office in 18 rue Jacqueline Auriol – 78280 Guyancourt (France) and company number 399 899 806 (“Asmodee” or “we”), is the controller of your personal data.

2. What personal data do we collect about you?

We collect information regarding you, such as:

  • Identification data, including your name and job title, birthdate, registration number, etc.,
  • Skype address,
  • Contact information including the identity and contact information of the company you work for and your email address, where provided,
  • Invoicing and payment information,
  • Information you provide to us for the purposes of attending meetings and events, including dietary restrictions,
  • Relevant information as required by Anti-Money Laundering and Anti-Bribery Regulations in the context of the Know Your Supplier personal data processing carried out as part of our suppliers intake procedures. This may possibly include documents obtained from you, and possibly information obtained from third party sources online or offline, and
  • Other information relevant to provision of services.

3. How do we use your personal data?

We use your personal data for the purposes listed below. Whenever we process your personal data, we do so on the basis of a lawful “justification” (or lawful basis) for processing, which we have identified in the table below.

Purpose for processing Lawful basis
1 To carry out administrative operations relating to agreements (including their execution), orders, receipt of deliveries, invoices, payments, accounting in relation to vendor accounts management, etc. This processing is necessary to perform the contract between you and Asmodee.
2 To prepare payment instruments (checks, bills of exchange, drafts, promissory notes). This processing is necessary to perform the contract between you and Asmodee.
3 To establish financial statistic and turnover statistics per vendor. We consider that we have a legitimate interest in conducting analysis regarding our activities to help us take business decisions.
4 To provide a selection of vendors for the needs of Asmodee. We consider that we have a legitimate interest in maintaining a list of our vendors to conduct our business operations.
5 To maintain a documentation on vendors. We consider that we have a legitimate interest in maintaining such a documentation to conduct our business operations.
6 To comply with any applicable law, court order, other judicial process, or the requirements of a regulator. This processing is necessary to comply with our legal obligations.
7 To enforce our agreements with you. We consider that we have a legitimate interest in ensuring that our contracts are performed correctly and in defending our rights where necessary.
8 We consider that we have a legitimate interest in ensuring that our contracts are performed correctly and in defending our rights where necessary. We consider that we have a legitimate interest in ensuring that our contracts are performed correctly and in defending our rights where necessary.
9 To protect the rights of third parties. This processing is necessary for the compliance with legal obligations to which Asmodee is subject.

This processing is also necessary for the purpose of the legitimate interests pursued by Asmodee. We consider that we have a legitimate interest in ensuring our activities do not violate any third parties’ rights.

10 In contemplation of and/or in connection with a business transaction such as a merger, or a restructuring, or sale. We consider that we have a legitimate interest as we need to be able to make decisions relating to the future of our business in order to preserve our business operations or grow our business.
11 We consider that we have a legitimate interest as we need to be able to make decisions relating to the future of our business in order to preserve our business operations or grow our business. We rely on your consent to collect information for the organization of marketing activities where you may be involved, to better serve you
12 To comply with our legal obligations in terms of suppliers verifications (including any Know Your Supplier, Anti-Money Laundering or Anti-Bribery regulations), conflicts or similar obligations including, but without limitation, maintaining regulatory insurance. This processing is necessary to comply with our legal obligations.
However, where such legal obligations result from laws other than EU or Member State law, then we consider that we have a legitimate interest in complying with such legal obligations when non-compliance may result in sanctions or other adverse consequences for our organization or the Asmodee group in general.

If you are an employee of one of Asmodee’s vendors, we only use your contact information for the management of the relationship with your employer. We consider that we have a legitimate interest in ensuring we can communicate with you and preserve our business operations with your employer.

4. Who do we disclose your personal data to?

We may share your personal data with a variety of the following categories of third parties as necessary:

  • Other entities of the Asmodee group (the list of Asmodee affiliates is available in Annex 1),
  • Third party service providers (maintenance, storage, payment, logistics, marketing services, reputation audits, etc.), for the purposes described in Section 3 above,
  • Our professional advisers such as lawyers and accountants, auditors,
  • Shareholders,
  • Government or regulatory authorities,
  • Professional indemnity or other relevant insurers,
  • Regulators/tax authorities/corporate registries,
  • Partners, and
  • Banks.

Please note this list is non-exhaustive and there may be other examples where we need to share with other parties where justified by our legitimate interest, permitted by applicable law, or necessary for compliance with a legal obligation to which we are subject.

In this context, your personal data may be transferred outside the European Economic Area (EEA), to countries not offering a level of protection of personal data equivalent to that offered within the EEA, such as China, USA, Canada, etc. In the absence of an adequacy decision of the European Commission, the transfer of your personal data will be made pursuant to standard contractual clauses adopted by the European Commission. You can obtain a copy of the relevant safeguard by contacting donneespersonnelles-group@asmodee.com, although some details may be redacted for confidentiality reasons.

5. How long do we retain your personal data?

Our general approach is to retain your personal data only for as long as required to fulfil the purposes for which it was collected. We generally retain your personal data for the duration strictly necessary for the management of our relationship with you.

However, we may retain personal data for longer periods of time, for instance where we are required to do so in accordance with legal, tax and accounting requirements, or where such data is necessary to establish the existence of a right or contract. In that case, your personal data will be archived and retained for the duration imposed by applicable law, or for the duration of the applicable statute of limitations.

When your personal data will no longer be necessary, we will delete or anonymize them.

6. Security of your personal data

We are committed to keeping your personal data secure and we have implemented appropriate information security policies, rules and technical measures to protect it from unauthorised access, improper use or disclosure, unauthorised modification and unlawful destruction or accidental loss.

All of our partners, employees, consultants, workers and data processors, who have access to, and are associated with the processing of personal data, are obliged to respect its confidentiality.

7. What are your rights?

You have a number of rights in relation to your personal data. More information about each of these rights is set out below:

  • Withdrawal of consent. You can withdraw at any time your consent in respect of any processing of personal data based on your consent, without affecting the lawfulness of processing based on your consent before its withdrawal.
  • Access. You can ask us to confirm whether we process your personal data and, as the case may be, inform you of the characteristics of such processing, allow you to access such data and give you a copy of it.
  • Rectification. You can ask us to rectify or complete inaccurate or incomplete personal data.
  • Erasure. You can ask us to erase your personal data in the following cases: where it is no longer necessary for the purposes for which it was collected; you withdrew your consent; you objected to the processing of your personal data; your personal data has been processed unlawfully; or to comply with a legal obligation. We are not required to comply with your request notably if the processing of your personal data is necessary for compliance with a legal obligation or for the establishment, exercise or defence of legal claims.
  • Restriction. You can ask us to restrict the processing of your personal data (i.e., keep but not use your personal data) where: the accuracy of your personal data is contested; the processing is unlawful, but you do not want it erased; it is still necessary to establish, exercise or defend legal claims; to verify the existence overriding grounds following the exercise of your right of objection. We can continue to use your personal data following a request for restriction, where: we have your consent; to establish, exercise or defend legal claims; or to protect the rights of another natural or legal person.
  • Portability. You can ask us to provide your personal data to you in a structured, commonly used, machine-readable format, or you can ask to have it ‘ported’ directly to another data controller, but only where the processing is based on your consent or on the performance of a contract with you, and the processing is carried out by automated means.
  • Digital legacy. You have the right to define (general or specific) directives regarding the fate of your personal data after your death.
  • Right to object to processing justified on legitimate interest grounds. Where we are relying upon legitimate interest to process personal data (see Section 3), then you have the right to object to that processing. If you object, we must stop that processing unless we can either demonstrate compelling legitimate grounds for the processing that override your interests, rights and freedoms or where we need to process the data for the establishment, exercise or defense of legal claims.
  • Right to object to processing for marketing purposes. Where we process personal data for direct marketing purposes, then you have the right to object to that processing at any time.

You also have the right to lodge a complaint with a supervisory authority if you consider that the processing of your personal data infringes applicable law. In France, the supervisory authority for the protection of personal data is the CNIL (www.cnil.fr).

8. Contact and complaints

For further information regarding your rights, to exercise any of your rights, or if you have any complaints or questions regarding the processing of your personal data, please contact donneespersonnelles-group@asmodee.com

9. Changes to this Privacy Notice

We may occasionally change this Privacy Notice, for example, to comply with new requirements imposed by the applicable laws, technical requirements or good commercial practices. We will notify you in case of material changes.

Annex 1

FINANCIERE AMUSE TOPCO, a French Société par actions simplifiée with a share capital of 290.491.411 euro, having its registered office at 18 rue Jacqueline Auriol, Quartier Villaroy – 78280 Guyancourt, registered with the Commerce and Companies Register of Versailles under number 842 440 778

FINANCIERE AMUSE MIDCO, a French Société par actions simplifiée à associé unique with a share capital of 290.011.411 euro, having its registered office at 18 rue Jacqueline Auriol, Quartier Villaroy – 78280 Guyancourt, registered with the Commerce and Companies Register of Versailles under number 842 440 810

FINANCIERE AMUSE BIDCO, a French Société par actions simplifiée à associé unique with a share capital of 289.931.411 euro, having its registered office at 18 rue Jacqueline Auriol, Quartier Villaroy – 78280 Guyancourt, registered with the Commerce and Companies Register of Versailles under number 815 143 904

ASMODEE HOLDING, a French Société par actions simplifiée with a share capital of 182.967.057,50 euro, having its registered office at 18 rue Jacqueline Auriol, Quartier Villaroy – 78280 Guyancourt, registered with the Commerce and Companies Register of Versailles under number 798 660 833

ASMODEE FRANCE, a French Société par actions simplifiée à associé unique with a share capital of 355.017,45 euro, having its registered office at 18 rue Jacqueline Auriol, Quartier Villaroy – 78280 Guyancourt, registered with the Commerce and Companies Register of Versailles under number 821 169 794

ASMODEE DIGITAL, a French Société par actions simplifiée, with a share capital of 5,000 euro, having its registered office at 18 rue Jacqueline Auriol, Quartier Villaroy – 78280 Guyancourt, registered with the Commerce and Companies Register of Versailles under number 818 058 216

JD EDITIONS, a French Société par actions simplifiée with a share capital of 450.984,00 euro, having its registered office at 18 rue Jacqueline Auriol, Quartier Villaroy – 78280 Guyancourt, registered with the Commerce and Companies Register of Versailles under number 312 680 671

DAYS OF WONDER, a French Société à responsabilité limitée with a share capital of 10,000 euro, having its registered office at 18 rue Jacqueline Auriol, Quartier Villaroy – 78280 Guyancourt, registered with the Commerce and Companies Register of Paris under number 443 656 277

UBIK, a French Société par actions simplifiée, with a share capital of 60,000 euros, having its registered office at 1 Rond-Point de Flotis, 31240 Saint Jean, registered with the Commerce and Companies Register of Toulouse under number 452 197 445

FLAT PROD, a French Société par actions simplifiée, with a share capital of 15,000 euros, having its registered office at 17 rue des Grands Champs, 45000 Orléans, registered with the Commerce and Companies Register of Orléans under number 512 950 254

ASMODEE UK HOLDING LIMITED, a British Company incorporated in the UK, with a share capital of 100 £ having its registered office at 27/28 Eastcastle Street, London, United Kingdom W1W 8DH, registered under number 11737872

ESDEVIUM GAMES LIMITED, a British Company incorporated in the UK, with a share capital of 55.550 £ having its registered office at 27/28 Eastcastle Street, London, United Kingdom W1W 8DH, registered under number 03055732

COILEDSPRING GAMES Ltd, a British Company incorporated in the UK, with a share capital of 33.000 £ having its registered office at 19 Napier House, Elva Way, Bexhill-on-Sea, East Sussex, United Kingdom, TN39 5BF , registered under number 04986141

ASMODEE BELGIUM, a Belgian société anonyme, with a share capital of 62.500 euro, having its registered office at 3070 Kortenberg, Jan Baptist Vinkstraat 4, Belgium, registered with the Register of Legal Persons under number 0429.666.250

PEARL GAMES, a Belgian limited company, with a share capital of 18.600 euros having its registered office rue 2B, rue Bas Forest – 7911 Fasnes-lez-Buissenal, Belgium, registered with the Register of Legal Persons under number 0564.749.638

ASMODEE HOLDING GmbH, a German Company incorporated in Germany, with a share capital of 25.000 euro having its registered office at Friedrichstr. 47, 45128 Essen (Germany), registered under number HRB29630

ASMODEE GmbH, a German Company incorporated in Germany, with a share capital of 275.000 euro having its registered office at Friedrichstr. 47, 45128 Essen (Germany), registered under number HRB382173

LOOKOUT GmbH, a limited liability company (Gesellschaft mit beschränkter Hatftung – GmbH), established under the laws of Germany, with a share capital of 25.000 euro with the commercial register (Handelsregister) of the local court (Amtsgericht) of Mainz under HRB 47617 and having its business address at Elsheimer Straße 23, 55270 Schwabenheim

ASMODEE EDITIONS IBERICA SLU, a Spanish company incorporated in Spain, with a share capital of 3.600 euros having its registered office at Calle Petróleo, número 24, Polígono Industrial San José de Valderas, Leganès Madrid, Spain, registered with the Spanish Tax Office under no. C.I.F B85385300

EDGE ENTERTAINMENT STUDIO, S.L. previously known as GLOBAL NEMBUS, a Spanish company incorporated in Spain, with a share capital of 3.600 euro having its registered office at Avenida Diego Martinez Barrio no 10, Edificio Insur, Planta 6a, 41013 Sevilla, Spain, registered with the Spanish Tax Office under number C.I.F. B87655205

ASMODEE ITALIA SRL, previously known as ASTERION PRESS SRL, an Italian limited company, with a share capital of 20.000 euro, having its registered office via Martiri di Cervarolo 1/B – 42015 Correggio, Italia, registered with the Register of Legal Persons under number 02200000350

ENIGMA DISTRIBUTION BENELUX, a Dutch company incorporated in The Netherlands, with a share capital of 100.000 euro, having its registered office at Wethouder den Oudenstraat 8, 5706 St Helmond, The Netherlands, registered with the Companies Register under number 53234715

ASMODEE NORDICS A/S (formerly ENIGMA DISTRIBUTION DANMARK A/S), a Danish company incorporated in Denmark, with a share capital of 2.500.000 DKK having its registered office at Valseholmen 1, 2650 Hvidovre, Denmark, registered with the Companies Register under number DK27519601

ENIGMA NORGE AS, with a share capital of 100.000 NOK having its registered office at Inkognitogata 33 A, 0256, Oslo, Norway, registered with the Companies Register under number 988 238 805

PLAYOTEKET AB, with a share capital of 100.000 SEK having its registered office at Clemenstorget 6, 222 21, Lund, Sweden, registered with the Companies Register under number 556656-1477

ENIGMA SVERIGE AB, with a share capital of 100.000 SEK having its registered office at Backa strandgata 18, 422 46 Hisings Backa, Västra Götalands Iän, Sweden, registered with the Companies Register under number 556718-9344

ENIGMA FINLAND OY, having its registered office at c/o Prego Oy DOCG, Juoksijantie 12, 02580 Siunto, Finland, registered with the Companies Register under number 2204165-5

REBEL Spółka z ograniczoną odpowiedzialnością (REBEL sp. z o.o), a limited liability company organized under the laws of Poland, with a share capital of PLN 3,822,100.00, with its registered office in Gdańsk, at ul. Budowlanych 64C, 80-298 Gdańsk, entered into the register of entrepreneurs held by the District Court Gdańsk-Północ in Gdańsk, VII Commercial Department of the National Court Register under KRS number 451062, with statistical number REGON 221833849 and tax identification number NIP 9571068214

Bezzerwizzer Nordic ApS, a limited liability company organized under the Laws of Denmark with its registered office at Valseholmen 1, 2650 Hvidovre – Denmark, registered with the Commerce and Companies Registry under number 31 85 42 29

ADC Blackfire Entertainment S.R.L, withs its business seat at 4-6 Daniel Danielopolu, 5th floor, Sector 1, Bucharest, Romania, registered with the commercial register under registration number J40/9027/2014

ADC Blackfire Entertainment s.r.o, ID No 257 88 418, with business seat at Novozámecká 4/495, 198 00 Prague, Czech Republic, registered with the commercial register maintained by the Municipal Court in Prague under file number C 70317

ADC Blackfire Entertainment GmbH, german company having its head office at Harkortstr. 34, 40880 Ratingen, registered under number HRB 25016

THE GREEN BOARD GAME COMPANY LIMITED having its head office at Unit 112 Coronation Road – Cressex Business Park, High Wycombe, Buckinghamshire, HP12 3RP, England, registered under number 02475241

LAGOON TRADING COMPANY LMITED having its head office at Unit 112 Coronation Road – Cressex Business Park, High Wycombe, Buckinghamshire, HP12 3RP, England, registered under number 02475241

GAMEGENIC GmbH, with a share capital of 25.000 euros, having its head office at Friedrichstrasse 47, 45128 Essen, registered under number HRB 30099

ASMODEE EDITIONS LLC. (US), an American company incorporated in Pennsylvania, U.S.A., with a share capital of $1,000 USD having its registered office at 1995 West County Road B2, Roseville, MN 55113, U.S.A., registered with the Companies Register under number EIN 20-2123892

ASMODEE NORTH AMERICA INC, a company incorporated in Minnesota, U.S.A., having its registered office at 1995 West County Road B2, Roseville, MN 55113, U.S.A., registered under number 8T-468

FANTASY FLIGHT EVENT CENTER LLC, (100% owned subsidiary of Asmodee North America) an American company organized in Minnesota, U.S.A. with a share capital of $25,000 USD.; having its registered office at 1995 West County Road B2, Roseville, MN 55113, U.S.A., registered with the Companies Register under EIN 27-1678018

ASMODEE CANADA INC., a company incorporated in Canada, with a share capital of $2 729 661 CAD having its registered office at 31 rue de la Coopérative, Rigaud, Québec, J0P 1P0, Canada, registered under number 1163659668

LION RAMPANT IMPORTS LTD, (100% owned subsidiary of Asmodee Canada Inc,) a company incorporated in Canada, having its registered office at 36 Easton Road, Brantford, Ontario, Canada

ILHAS GALÁPAGOS COMÉRCIO DE BRINQUEDOS E SERVIÇOS LTDA.-EPP, a Brazilian limited liability company, with a share capital of R$ 2.400.000, with head offices at Rua Mourato Coelho, 936, Suite 31, CEP 05417-001, São Paulo, State of São Paulo, enrolled with the CNPJ/MF under No. 15.605.065/0001-38

IMPORTADORA Y COMERCIALIZADORA SKYSHIP SpA, a company by shares (sociedad por acciones) organized under the laws of Chile, with its registered office at Dr. Manuel Barros Borgoño 106, office No. 306, borough of Providencia, Santiago, Chile, registered at Registry of Commerce of Santiago and tax identification number 76.353.094-9

ASMODEE TRADING (Shanghai) Co. Ltd, with a share capital of 200.000 euros having its registered office at 1295, rue South Suzhou, Bureau 209, 200003 Shanghai, China, registered under number 913100000512704061

ASMODEE ASIA Ltd, a company organized under the law of Hong Kong, with a share capital of 50.000 HKD having its registered office at RM1309, 13/F HO King Comm CTR, 2-16 FA Yuen St Mongkok Kln, Hong Kong, registered under number 67839282 – 000 – 06 17 -9

ASMODEE TAÏWAN (formerly KIDS POWER INTERNATIONAL LTD.) company 53100400, office at 3F, No35, Ln 60, Wenhu St, Neihu Dist, Taipei City, Taiwan (R.O.C.)

FOREVER BRIGHT (Shenzhen) Limited Company, Limited Liability Company, having its registered office at Floor 1, 2 & 3, Building CS, Fuyuan Industry Zone, n° 598 Zhoushi Road, Hangcheng Street, Bao’an District, Shenzhen, registered under number 91440300781353326B

SHENZHEN WIDE WEST TECHNOLOGY LIMITED, Limited Liability Company, having its registered office at 4F East Area, lnvestment Promotion Development Center, Nanhai Avenue, Shekou, Nanshan District, Shenzhen, registered under number 9144030076918550XW

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