PRIVACY POLICY

Last Updated: September 22, 2023

GameStop's Commitment to Privacy

At GameStop Canada we are committed to your right to privacy. We collect personal information from our customers in the regular course of doing business. We have developed this Privacy Policy to explain our practices for the collection, use, and disclosure of your personal information.

This Policy applies to our GameStop retail stores (collectively, "GameStop Stores"), our websites and to any other channels owned or operated by GameStop Canada that are used for the sale of products or services. All references to "websites" in this Privacy Policy mean www.gamestop.ca, www.ebgames.ca, or other GameStop Canada-provided websites (collectively, the "GameStop Websites").

How Do We Obtain Your Consent to the Collection of Your Personal Information?

When you provide us with personal information to complete a transaction, place a pre-order, provide feedback, make an inquiry or return a purchase, we assume you consent to our collecting your personal information and using it for that specific purpose.

If we ask you for personal information for a secondary purpose, like contests, we will either ask you directly for your consent or provide you with an opportunity to say no. If you accept an offer made by any of our third party marketing partners, we will disclose your relevant personal information, including name, and address, to that third party, in accordance with the terms of the offer.

Express and Implied Consent – We may ask you to give your express consent, such as by checking a box to indicate your consent to receive marketing communications, or by providing your signature to indicate your acceptance of the use and disclosure terms presented on an application form. Other times, where permitted by applicable laws we may obtain your consent implicitly when we can reasonably conclude that you've given consent by some action you have taken or an action you have decided not to take. Generally, this occurs where the purpose for use of your personal information would be reasonably apparent to you or a natural extension of a purpose for which you have provided your express consent. For example, when you enter a GameStop Store, your attendance and activities in that GameStop Store may be recorded by our security cameras. By entering any GameStop Store you therefore implicitly consent to such recordings being created, used and retained for our internal security purposes and to investigate any security or unlawful incident that may occur at or near a GameStop Store, as well as to use in any civil or criminal proceedings to the extent the foregoing is relevant.

You may notify us at any time if you wish to withdraw or change your consent. Further details can be found in the Your Privacy and Access Choices section below.

When you choose to provide us with your personal information you consent to the use, disclosure and retention of your personal information as provided in this Privacy Policy and as may be further provided at or prior to the time of collection.

What Information Do We Collect About You?

At GameStop Canada, we collect both personal information and non-personal information. The types of information we collect depend on the nature of your interaction with us. You may choose not to provide us with your personal information. However, if you make this choice we may not be able to provide you with the product, service, or information that you requested.

Personal information is information that can identify an individual or information about an identifiable individual. We may collect personal information including the following:

• contact information – your name, postal address, telephone number, and email address (or that of your parent or legal guardian if you are a minor)
• validation information - your driver's licence number or other government identification number (please note that we never collect your social insurance number or health card number)
• personal preferences – opinions, interests, hobbies, product wish lists, language preferences, and marketing consent; and
• financial information and transaction information – products purchased, method of payment, amount paid, credit or debit card number and other billing information.

Some information collected by GameStop does not directly identify you as an individual but may still be classified as personal information. For example, we may collect certain digital identifiers when you visit the GameStop Websites, such as your Internet Protocol address, or the type and version of browser you are using or the referring URL.

We may also collect non-personal, aggregate, or non-identifiable information which is not subject to this privacy policy.

How Do We Use Your Personal Information?

The primary reasons we collect personal information from you are:

• to complete a sales transaction with you
• to place pre-orders on your behalf
• to fulfill your requests for products, services or information
• to process trades
• to process applications and other matters relating to Edge loyalty program memberships
• to limit the possibility of fraud or error when we process your transactions, refunds and/or exchanges
• to administer rebates
• to conduct contests, promotions or surveys

We also use your personal information for other, secondary reasons, including:

• Customer service
• Customer experience
• As part of extended service agreements
• To administer a loyalty program, including but not limited to tracking and analyzing your purchases and preferences to better understand your product and service needs and eligibility
• To facilitate your acceptance of offers made by our third party marketing partners
• To tailor our online content based on your preferences
• To measure and improve the effectiveness of the GameStop Websites or our promotions and marketing endeavours
• To follow up and inquire in terms of your activities on GameStop Websites or interruption of certain activities on GameStop Websites
• To assess demand for our products and services
• If you ask us, to offer and promote additional products and services we offer
• For other purposes as described in this Privacy Policy
• For other purposes disclosed to you at or prior to the time of collection
• As otherwise provided, permitted or required by law

Information GameStop Canada Collects Directly from You

Returns and Exchanges – In connection with any returns, refunds or exchanges, we ask for personal information such as your name, address, email address and telephone number for the purposes of detecting and preventing fraud.

Purchase Follow-Up and Surveys - Following a purchase, we may send you a follow-up letter either thanking you for your business or inquiring as to whether you are satisfied with your purchase. We may use contact information collected from you to conduct occasional surveys and other customer research. These surveys are entirely voluntary.

GameStop Stores – When you enter an EB Game Store your visit and activities in such EB Game Store will be recorded by our security cameras and retained and may be used for our internal security purposes as well as in conjunction with investigations, the preservation or enforcement of our rights and remedies, and/or any civil or criminal proceedings.

GameStop Websites – You can browse GameStop Websites without having to provide us you're your name. However, to order products and services from GameStop Websites, or to use special features or functions of GameStop Websites, you may be asked to provide personal information, such as your name, email address, postal address, telephone number, or credit or debit card information. We use this information to create your account, contact and correspond with you about your account or order, respond to your inquiries, and monitor functions or features of GameStop Websites that you may use.

Customer Reviews and Posted Content – We may provide you with the ability to rate or review products or services we sell, or otherwise post content on the GameStop Websites. Any comments or reviews that you provide are accessible to all visitors to GameStop Websites, so you should use discretion when posting information and you should not post personal information. GameStop Canada has no responsibility if you do post personal information on any GameStop Website but will promptly remove such personal information if you make such request in writing. Subject to the other provisions of this privacy policy relating to your personal information, you grant a perpetual worldwide non-exclusive license to GameStop Canada to copy, use and/or display any content that you post on any GameStop Website.

Newsletters or Updates - GameStop Canada may also offer you the opportunity to sign up for newsletters or other promotional communications. If you decide to do so, we will collect your contact information, such as name and email address. This information will only be used to send you the newsletter and promotional announcements that you have requested. You may "unsubscribe" at any time by using the unsubscribe link included in the footer of the newsletter or by using the unsubscribe link included below under the heading "Unsubscribe". We do not rent our subscriber list or offer to sell it to other parties.

Contest and Other Promotions - From time to time, we may run contests or promotions. If you participate, you may be asked for contact information, confirmation that you have reached the age of majority in the province in which you reside and satisfy other eligibility requirements, as well as additional optional survey information (for example, product preferences). Personal information from contest entries will be used only to administer the contest and contact you if you win. For research and analysis purposes, we may also aggregate contest survey information in a manner that no longer identifies individual participants. All contests and promotions are subject to this Privacy Policy and the rules provided for each particular contest or promotion. If a contest is sponsored by a third party, it will be subject to the third party's contest rules and policies.

Subscription Services and Activations - GameStop Canada may offer activation of certain products and services like online games, downloadable games or game components, or Internet services. These activations may require that certain contact and financial information be collected and provided to GameStop Canada or to its respective service providers as part of the activation process.

Call Centres - GameStop Canada operates customer support call centres to respond to your questions, concerns, or complaints regarding our products or services. When you contact our call centres, we may ask for personal information to help us respond to your inquiry or to verify your identity. For example, if you have a question about the status of a recent online order, we will ask for personal information to verify that you are the account holder. We may also monitor or record your telephone discussions with our customer support representatives for training purposes and to ensure service quality.

EDGE Loyalty Program - If you apply to register as a member to our EDGE loyalty program, you will be required to provide the following information: (i) first name; (ii) last name; (iii) date of birth; (iv) email address and type of e-mail account; (v) preferred language of communication; (vi) GameStop Store where application process is initiated; and (vii) phone number / mobile number. The following information may be provided at your discretion: (i) gender; (ii) profile photo; and (iii) postal code.

Information GameStop Canada Collects Automatically

GameStop Websites - When you visit the GameStop Websites, we may collect the Internet Protocol (IP) address of your computer and of your Internet service provider, the date and time you access the GameStop Websites, the Internet address of the website from which you linked directly to a GameStop Website, the computer operating system you are using, the sections of the GameStop Website you visit, the GameStop Website pages read and images viewed, and the content you download from the website. This information is used for website and system administration purposes and to improve the GameStop Websites.

Cookies - GameStop Canada may use cookies to store your individual preferences and system information. "Cookies" are small electronic data files that websites can store on your computer for record keeping purposes. For example, cookies will remember what you've placed in your shopping cart, and tell us that you have visited one of the GameStop Websites before. Cookies also may be used on the website for other reasons, such as to limit the number of times you have to enter a password or enter your language preference, to offer personalized web page content and information for your use, and to track your activity at the GameStop Website. The use of cookies is standard in the Internet industry and many websites use them. In addition, you may modify your browser's settings to notify you whenever a website is going to deposit a cookie on your computer's hard drive or other storage media. The notification option generally gives you the opportunity to decide whether to accept or refuse a cookie in each instance. You can configure your browser to always disable cookies when cookies are being sent to your computer, although this may affect your ability to shop online, both at GameStop Canada and elsewhere.

Website Tracking Information – Web beacons are tiny graphics with a unique identifier, similar in function to cookies, and are used to track the online movements of web users. We may use web beacons (sometimes called "clear gifs", "web bugs" or "pixel tags") to compile tracking information reports regarding website user demographics, website traffic patterns, and website purchases. We may then provide these reports to advertisers and others. None of the tracking information in these reports can be connected to the identities or other personal information of individual users. In addition, we may use web beacons in our HTML-based emails to let us know which emails have been opened by the recipients. This allows us to gauge the effectiveness of certain communications and the effectiveness of our marketing campaigns. If you do not want to receive these emails, please see the "unsubscribe" section below. For GameStop Canada's own research purposes we may link tracking information with personal information voluntarily provided by website users. Once such a link is made, all of the linked information is treated as personal information and will be used and disclosed only in accordance with this Privacy Policy.

Analytics Information - We use the third party tools and services to measure traffic to GameStop Websites and how users interact with GameStop Websites. This includes third parties such as Google Analytics (Privacy Policy), Meta (Privacy Policy), Optimizely (Privacy Policy), New Relic (Privacy Policy), Mouseflow (Privacy Policy). As part of these services third parties may process the following categories of personal information: identifiers, device information, demographic data, online activity, or inferences derived from your activity on GameStop Websites.

Third Parties and Service Providers – GameStop utilizes other third parties and service providers to operate the GameStop Websites. This includes vendors such as BlueCore (Privacy Policy), Alphabet (Google) (Privacy Policy), Meta (Privacy Policy), Acoustic (Privacy Policy), Zendesk (Privacy Policy). Please note that although third parties may collect information about you in conjunction with your visits and use of GameStop Websites, GameStop Canada only receives aggregated data and we do not actually receive personal information about either you or any other user of any GameStop Website. We would therefore invite you to access and review each such third party's own privacy policy to determine how they collect, use, process, retain and communicate personal information. In some instances, it may be possible for you to configure your web browser to prevent the collection of some of the information that such third parties collect when you are visiting one of the GameStop Websites.

Your Choices With Respect To Digital Technologies – You may block digital technologies in your browser or device settings, as and if permitted by such device, but in some circumstances, disabling these features may interfere with your ability to access our products or services.

Social Media Platforms - If you use embedded features on a GameStop Website that posts content or otherwise links to your Facebook, Google, X (Formerly Twitter) or other social media account, we will obtain general details about your social media account such as your username and what content on the GameStop Website you choose to share with other via one of your social media accounts.

Links to Other Websites - The GameStop Websites may contain links that permit you to link to other websites or Internet resources. When you click on one of those links you are connecting to another website or Internet resource. GameStop Canada has no responsibility or liability for, or control over, those other websites or Internet resources or their collection, use and disclosure of your personal information. We encourage you to read the privacy policies of those other websites before you submit any personal information to them.

Data on Returned Product – If you return products that may contain stored or recorded personal information, like computers, game consoles, etc., you are responsible for deleting or removing all personal information and media from your product before you return it. GameStop Canada is not responsible for any personal data or media that you do not delete or remove from such product.

Supplementing Information - From time to time we may supplement or editorialize information you give us with information from other sources, such as information validating your address or other available information you have provided to us. This is to help us maintain the accuracy of the information we collect and to help us provide better service.

Does GameStop Canada Share Your Information?

GameStop Canada does not sell or rent our customers' personal information to any other party. However, in the normal course of business we may share some of your personal information within our corporate family internationally and with third parties (such as agents, mandataries or service providers) acting on our behalf, or as permitted or required by law.

In addition, if you accept an offer from any of our third party marketing partners, we will share your contact with that specific third party, in accordance with the terms of the offer. If you have previously requested that your personal information not be shared with third party marketing partners, but then later consent by accepting a third party marketing offer available through one of the GameStop Websites, we will share your contact and billing information with that specific third party, in accordance with the terms of the offer.

Some of these operations may result in personal information collected by GameStop Canada being stored or processed outside of Canada (including, the United States) and, as a result, your personal information may be accessible to law enforcement and regulatory authorities in accordance with the law of these foreign jurisdictions.

Service Providers - GameStop Canada may use third parties to manage one of more aspects of our business operations, including the processing or handling of personal information. We may share personal information with such third parties to perform services on our behalf such as fulfilling online orders, processing non-cash payments, sending marketing communications, servicing products, technology services, conducting research surveys, verifying and validating information that you have provided to us, delivering products, and providing customer support services. When we do use an outside service provider, we use contractual and other appropriate means to ensure that your personal information is used and safeguarded in a manner that is consistent with this Privacy Policy.

GameStop Canada has taken precautions to prevent the fraudulent use of your information on the GameStop Websites. GameStop Canada has adopted industry standard authentication procedures to ensure your protection while shopping with us online. This includes, but is not limited to, contacting financial institutions or credit reporting agencies to ensure the authenticity of your credit card and to validate your credit card billing information.

Information Shared with Parent and Affiliates - GameStop Canada may share personal information gathered on the GameStop Websites within its organization (including its retail stores) and with its corporate parent (domiciled in Luxembourg), and affiliates (including, affiliates domiciled in the United States) for internal business purposes in accordance with this Privacy Policy. If GameStop Canada shares your information within its corporate family, we will ensure that your information continues to be used only in accordance with this Privacy Policy and your expressed choices.

Information Shared with Financial Firms, Institutions and Organizations – We may from time to time provide you with the option to obtain a loan or other financing from a third-party financial firm, institution or organization (a "Lender") in regard to your purchase of a particular product through a GameStop Website. Should you have any interest in obtaining such purchase loan or financing, you will be redirected to the Lender's lending portal where you will be able to complete and submit an application and through which such application will be processed and approval or rejection of such application will be communicated to you. In conjunction with the foregoing, we may share information about you with such Lender including, your name, IP address, shopping cart content and total transaction value . Please note that GameStop Canada has no involvement with such loan or other financing and any personal information solicited in terms of any pre-approval or application is being collected by the underlying Lender directly and such collection and handling thereof will not be subject to this Privacy Policy but will rather be subject to the Lender's own privacy policy. You should therefore ensure that you carefully review such Lender's privacy policy prior to disclosing any personal information.

Product Safety Recalls - In the event we receive notice from a manufacturer or supplier of a product safety recall, we may provide your contact information, limited to name, address and telephone number, to the manufacturer so that they may notify you of the recall and supply details of any replacement or repair programs. This transfer of your contact information will occur only for recalls that may impact your personal safety or impair the functionality of the product you purchased from us.

Sale or Transfer of Business or Assets of GameStop Canada - Any information we have about you may be transferred or disclosed to a purchaser or prospective purchaser in the event of a sale, assignment, or other transfer of all or a portion of our business or assets either directly or indirectly (including one affecting or relating to GameStop Canada' parent). Should such a sale, assignment or other transfer occur, we will use reasonable efforts to ensure that the transferee uses your information in a manner that is consistent with this Privacy Policy.

Legal Disclosure - GameStop Canada may disclose your information as permitted or required by law. For example, we may be compelled to release information by a court of law or other person or entity with jurisdiction to compel production of such information. If we have reasonable grounds to believe information could be useful in the investigation of improper or unlawful activity, we may disclose information to law enforcement agencies or other appropriate investigative bodies.

International Transfers - GameStop Canada is headquartered in Canada; however, please be aware that information you provide to us or that we obtain as a result of your use of our services may be collected in your jurisdiction and subsequently transferred to, maintained and/or processed outside of your jurisdiction (including for residents of the province of Quebec, outside of Quebec), including in the United States or another jurisdiction by us or our service providers for the purposes mentioned above, in accordance with applicable law. Personal information processed and stored in another country may be subject to disclosure or access requests by the governments, courts or law enforcement or regulatory agencies in that country according to its laws.

How does GameStop Canada Protect Your Information?

GameStop Canada takes appropriate steps to protect your personal information. We maintain appropriate safeguards and current security standards to protect your personal information against unauthorized access, disclosure, or misuse. For example, electronic records are stored in secure, limited-access servers; electronic data is stored behind secured encryption access; we use technological tools like firewalls and passwords; and we ensure our employees are trained on the importance of maintaining the security and confidentiality of personal information.

SSL Technology - GameStop Websites use encryption technology, such as Secure Sockets Layer ("SSL"), to protect your personal information during data transport. SSL encrypts ordering information such as your name, address, and credit card number.

Choosing a Password - When you create an online account on GameStop Websites, you will be prompted to select a personal password. To maximize your level of protection, you should choose a strong personal password, which means that passwords must be at least 8 characters long and contain at least: one number, one lowercase letter and one uppercase letter. You are solely responsible for maintaining the secrecy of your password and any account information. GameStop Canada will never send an unsolicited communication asking you for your password or requesting that you update and disclose your account credentials or any billing or payment information. WE WILL NEVER REQUEST THAT YOU DISCLOSE YOUR SOCIAL INSURANCE NUMBER, HEALTH INSURANCE NUMBER, PASSWORDS OR ANY OTHER SENSITIVE INFORMATION ONLINE OR BY E-MAIL. BE CAREFUL WHEN CLICKING ON ANY HYPERLINKS EMBEDDED IN ANY E-MAIL ADVISING YOU OF ANY SUSPENSION OF ACCOUNT, TRANSACTION CONFIRMATION OR THE LIKE AND ALWAYS CAREFULLY LOOK AT THE URL OF THE SITE YOU ARE REDIRECTED TO AND ENSURE THAT YOU ARE IN FACT ON A GameStop Website AND NOT AN ILLEGITIMATE IMITATION THEREOF. Although we cannot take responsibility for any theft, misuse, unauthorized disclosure, loss, alteration or destruction of data by a third party, we take reasonable precautions to prevent such occurrences.

Your Privacy and Access Choices

How to Change or Withdraw Your Consent - You may notify us at any time that you wish to withdraw or change your consent to our use and disclosure of your information. We will accommodate your request following receipt of such notice, subject to legal and contractual restrictions related to your transactions and the preservation of any rights and remedies that we may have as well as preservation of any evidence. Again, the withdrawal of your consent or your request limiting our ability to use, retain or communicate your personal information may prevent the delivery of products to you or your access to and/or use of the GameStop Websites.

If you have "opted in" or subscribed to one of our newsletters or mailing lists, we will always provide you the opportunity to "opt out" or unsubscribe. For example, each e-newsletter we send to you will include a link or other method to unsubscribe or decline further e-newsletters. See the Marketing Communications section below.

Access or Correct Your Information - You may check your information to verify, update, or correct it, and to have any obsolete information removed. If you created an account on one of the GameStop Websites, you can access and change your online account profile yourself. You can also ask to review any of the information that we have retained, how we have used it, and to whom we have disclosed it. at any time by contacting us as indicated below under the heading "Contacting GameStop Canada". Subject to certain exceptions prescribed by law, and provided we can authenticate your identity, you will be given reasonable access to your personal information, and will be entitled to challenge the accuracy and completeness of the information and to have it amended as appropriate. You may also ask us to change your preferences regarding how we use or disclose your information, or let us know that you do not wish to receive any further communication from us.

Contacting GameStop Canada

GameStop Canada is responsible for all personal information under its control. Our Privacy Officer is accountable for GameStop Canada's compliance with the principles described here. If you have any questions, concerns or complaints about the privacy practices of our organization, or wish to exercise your privacy rights, please contact us at the following link or via email.

You may contact our Privacy Officer by email or by mail at:

Privacy Compliance GameStop
Electronics Boutique Canada Inc.
8995 Airport Road
Brampton, Ontario
L6T 5T2

We will promptly respond to your request or investigate your concern but no later than 30 days from the date of receipt of your query and validation of your identity in terms of any inquiry or request relating to your personal information.

Marketing Communications

If you no longer wish to be contacted regarding email marketing, promotions, new product and entertainment releases click here (if currently signed out of your GameStop account) or click here (if currently signed in to your GameStop account).

When is Your Information Removed?

We keep your information only as long as we need it for legitimate business purposes and to meet any legal requirements. We have retention standards that meet these parameters. We securely destroy your information when it is no longer needed, or we remove your personally identifiable information to render it anonymous.

Children's Privacy

We do not knowingly collect any personal information from minors under the age of 14 without parental consent. If we learn that a child for whom parental consent is required has provided us with personal information, we will use reasonable efforts to delete it.

Who is GameStop Canada?

The GameStop Websites and GameStop Stores are owned and operated by Electronics Boutique Canada Inc. (cob GameStop).

Changes to this Privacy Policy

To accommodate changes in our services, changes in technology, and legal developments, this Privacy Policy may change over time without notice to you. We may add, change, or remove portions of the Privacy Policy when we feel it is appropriate to do so. We encourage you to review our Privacy Policy periodically and, more specifically, the date of last revision set forth at the very beginning of this Privacy Policy. Each time you submit personal information or use our services you agree to be bound by the then current terms of the Privacy Policy. Whenever we update the Privacy Policy we will change the date to indicate when the changes were made. Personal information previously provided will be subject to the version of the Privacy Policy in effect at the time of collection or at the time of consent (as the case may be).