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Announcement of Transfer of Personal Data Following Merger Please be notified that Smilegate Entertainment, Inc. (“we ” or the “Merged Company ”) will be merged with and into Smilegate Holdings, Inc. (“Smilegate Holdings ”) as of December 31, 2025 (the “Merger ”). In line with the Merger, personal data of our clients and trading partners and officers and employees under our possession will be transferred to Smilegate Holdings on the date of the Merger. (However, please be noted that the dates of the Merger and transfer of personal data are subject to change or postponement, and changes, if any, in such dates will be further announced.)
Who is Responsible?
The following companies are responsible for the processing of personal data within the transfer:
- Merged Company, as the transferor:
Smilegate Entertainment, Inc.
- Smilegate Holdings, as the transferee:
Smilegate Holdings, Inc.
What Data Are We Transferring?
We will transfer the personal data of our clients and trading partners and officers and employees that we hold at the time of the Merger and that are needed to conduct our business activities. Depending on the data subjects, the following categories of data that we have collected will be transferred:
• Data collected when you contact with any queries or complaints regarding Sierra Squad:
Why Are We Transferring the Data?
Your personal data will be transferred for the purpose of effectuating the Merger, based on Merged Company’s and Smilegate Holdings’s legitimate interest to internally reorganize and thus promote enterprise value by enhancing management efficiency. We will only transfer the data which is strictly necessary for the described purpose. The data will be transferred to Smilegate Holdings’s competent departments and will not be passed on or used for any unforeseen or unexpected purposes.
How Will the Data Be Processed Post-Merger?
Smilegate Holdings is committed to the safe management of the personal data transferred from the Merged Company in accordance with applicable laws and regulations, including the Personal Information Protection Act and the General Data Protection Regulation, and will use and process the transferred data only within the same scope and for the same utilization purpose as the Merged Company prior to Merger (currently available at: https://www.playcfss.com/privacypolicy.html ). Details on the personal data processing following Merger are provided in the Smilegate Holdings’s privacy notice.
What Rights Do You Have?
You have the right to object to the processing of your personal data based upon our legitimate interest or other legal authorization recognized in your jurisdiction. If you do not want your personal data to be transferred as part of the Merger, please contact : sge_contact@smilegate.com.
We will handle your request promptly and diligently and inform you about the balancing exercise we performed to support processing based upon such legal basis.
As recognized in your jurisdiction, you also have the right to access, rectification, erasure, restriction of processing and data portability with regard to your personal data, and you can lodge a complaint with a supervisory authority (as a rule, you can contact the supervisory authority of your usual place of residence).
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We assure you that Smilegate Holdings, which starts afresh following the Merger, will maximize its enterprise value as well as the value of its shareholders and employees by strengthening management efficiency and will remain dedicated to serving your interest. Thank you.
November 27, 2025
Smilegate Entertainment, Inc.
