VCO: Victor Charlie One

Survey & Prize Draw Privacy Notice

Systems Heavy Inc.

Effective Date: 3 November 2026

1. Introduction

Systems Heavy Inc. ("Systems Heavy", "we", "us" or "our") respects your privacy and is committed to protecting your personal data.

This Privacy Notice explains how we collect, use, store, share and protect personal information provided through our VCO: Victor Charlie One ("VCO") player feedback survey and associated promotional prize draw at Games Ground Berlin 2026.

It also explains your rights under the General Data Protection Regulation (EU) 2016/679 ("GDPR").

This notice supplements our general Privacy Policy and applies specifically to the survey and associated prize draw.

Participation is voluntary and restricted to individuals aged 18 years or older.

2. Who Is Responsible for Your Data?

The data controller responsible for the processing described in this notice is:

Systems Heavy Inc.

8 The Green, STE B

Dover, Delaware 19901

United States

Privacy Contact: Socials@SystemsHeavy.com

Systems Heavy is a corporation incorporated in the United States.

For questions regarding this Privacy Notice, requests concerning personal information or the exercise of your data protection rights, please contact us using the details above.

We will respond to valid requests in accordance with applicable data protection legislation.

3. Information We Collect

When you participate in the survey or associated prize draw, we may collect the following categories of information:

a. Survey Responses

• Confirmation that you are at least 18 years old.

• Selected age range.

• Responses to questions about gameplay, preferences and experiences.

• Optional written feedback, comments or suggestions.

We do not request your date of birth or identity documents to verify your age.

The survey does not collect gameplay scores, completion times or Player IDs.

Please do not include sensitive personal information, such as health information, religious beliefs or other special-category data, in optional written responses.

b. Prize Draw Information

• Email address supplied manually by you.

• Confirmation of acceptance of the Prize Draw Terms & Conditions.

• Information necessary to administer your entry and the selection of winners.

c. Marketing Preferences

• Your optional choice to receive marketing communications.

• Records of your consent and any subsequent withdrawal.

d. Winner Information

If you are selected as a winner, we may additionally request:

• Full name.

• Postal delivery address, where applicable.

• Information reasonably necessary to arrange prize delivery or fulfilment.

• Information required to coordinate participation in a game-related creative experience, where applicable.

We collect this additional information only from selected winners and only where reasonably necessary.

4. How and Why We Use Your Information

We process personal data for the following purposes and under the following lawful bases:

a. Game Development and Research

We analyse survey responses to understand player experiences, identify usability issues, evaluate gameplay mechanics and inform the ongoing development and improvement of VCO.

Lawful basis: Legitimate interests — Article 6(1)(f) GDPR.

Our legitimate interest is to research, evaluate and improve our products and services.

b. Prize Draw Administration

We use entry information to manage the Prize Draw, verify eligibility, select winners at random, contact winners and arrange delivery or fulfilment of prizes.

Where a prize involves a creative experience, such as helping design a character for VCO, we may use relevant contact and participation information to coordinate the activity.

Lawful basis: Performance of a contract — Article 6(1)(b) GDPR, based on the applicable Prize Draw Terms & Conditions.

c. Marketing and Playtesting Invitations

If you separately opt in, we may use your email address to send communications concerning Systems Heavy and its games, including development updates, announcements, promotions and opportunities to participate in future playtesting.

Lawful basis: Consent — Article 6(1)(a) GDPR.

Marketing consent is optional, is not required to enter the Prize Draw and may be withdrawn at any time.

Declining or withdrawing marketing consent will not affect your eligibility for the Prize Draw.

d. Legal Compliance and Protection

We may process limited information where necessary to comply with applicable legal obligations, maintain required records, administer the Prize Draw fairly, prevent misuse or establish, exercise or defend legal claims.

Lawful basis: Legal obligation — Article 6(1)(c) GDPR, or legitimate interests — Article 6(1)(f) GDPR, as applicable.

5. Age Restrictions and Participation

The survey and associated Prize Draw are available only to individuals aged 18 years or older who attend Games Ground Berlin 2026 in person.

Participants must confirm that they meet this minimum age requirement before proceeding.

Individuals who indicate that they are under 18 will not be permitted to complete the survey or enter the Prize Draw.

We do not knowingly accept completed survey entries from individuals under 18.

If we become aware that an ineligible individual has submitted personal information, we will take reasonable steps to remove that information, subject to applicable legal requirements.

Participation in the Prize Draw requires completion of the mandatory survey questions, acceptance of the Prize Draw Terms & Conditions and provision of a valid email address.

Optional written feedback and marketing consent are not required.

6. Separating Survey Responses and Contact Information

We aim to minimise the amount of identifiable personal information used in our research.

Email addresses collected for prize administration and optional marketing may initially be recorded alongside survey responses within Google Forms.

We separate contact information from research datasets when processing the collected information and restrict access to identifiable records to authorised personnel who require them for legitimate operational purposes.

Where reasonably practicable, survey results are analysed without direct personal identifiers.

We may combine and anonymise survey results to produce statistics, reports and summaries for internal development or external communication.

Such anonymised findings may be shared with publishers, investors, business partners or the public, provided individuals cannot reasonably be identified.

Before retaining or sharing feedback as anonymised information, we take reasonable steps to remove identifying details, including any personal information inadvertently included in written responses.

We do not sell participants' personal data or provide identifiable survey responses to third parties for their independent marketing purposes.

7. How We Store and Share Information

Our survey is administered using Google Forms, with responses and related information managed through Google Workspace services, including Google Sheets where applicable.

These services may process data on our behalf for the purposes of providing storage, administration and technical functionality.

Access to information is limited to authorised Systems Heavy personnel and contractors, who may operate from the European Economic Area, United Kingdom or United States.

We may also share limited personal data with:

• Service providers supporting Prize Draw administration, email delivery or communications.

• Postal and courier providers responsible for delivering physical prizes.

• Service providers reasonably necessary to fulfil digital or experiential prizes.

• Professional advisers, regulatory authorities or other recipients where disclosure is legally required or justified.

Service providers are given access only to information reasonably necessary for their responsibilities and are subject to applicable confidentiality and data protection requirements.

Google may separately process technical information necessary to operate and secure its services, in accordance with its applicable privacy terms.

8. International Data Transfers

Systems Heavy Inc. is incorporated in the United States. Personal data collected through the survey may be processed or accessed by authorised Systems Heavy personnel located in the United States, United Kingdom and European Economic Area.

We use Google Workspace to collect, store and manage survey information.

Google LLC participates in the EU–US Data Privacy Framework and is covered by the European Commission's adequacy decision for participating US organisations, to the extent applicable to the processing concerned.

The United Kingdom is also recognised by the European Commission as providing an adequate level of data protection.

Where we transfer personal data to another organisation in a country without an applicable adequacy decision, we use an appropriate legal transfer mechanism, such as the European Commission's Standard Contractual Clauses, where required. Other lawful transfer mechanisms may apply in specific circumstances.

Prize fulfilment may involve sharing limited delivery information with postal, courier or other fulfilment providers operating outside the European Economic Area. Such disclosures will be limited to information reasonably necessary for fulfilment and handled in accordance with applicable data protection requirements.

You may request further information about applicable international transfer safeguards by contacting Socials@SystemsHeavy.com.

9. How Long We Keep Your Information

We retain personal data only for as long as reasonably necessary for its intended purpose, subject to any applicable legal or regulatory requirements.

Our retention periods are as follows:

a. Prize Draw Entrants Who Do Not Win

Email addresses collected solely for Prize Draw administration will be deleted within 90 days after completion of prize fulfilment.

If you separately consented to marketing, your email address may continue to be retained for that purpose under the marketing retention arrangements below.

b. Prize Draw Winners

Winners' names, postal addresses and related prize delivery or fulfilment records will ordinarily be retained for up to 12 months after prize fulfilment, unless a longer period is required by applicable law or to resolve an outstanding claim.

c. Identifiable Survey Information

Personal identifiers and other information capable of linking survey responses to identifiable participants will be removed or anonymised within 90 days after prize fulfilment, unless a longer period is legally necessary.

d. Anonymised Research Data

Genuinely anonymised aggregated survey findings and non-identifying feedback may be retained indefinitely for research, historical analysis and game development.

e. Marketing Information

Where you have opted in to marketing, we retain the information necessary to communicate with you until you withdraw your consent or the information is no longer required.

We periodically review marketing records and remove information that is no longer necessary, subject to retaining limited suppression records where appropriate to honour opt-out requests.

Retention and deletion procedures apply to working copies, exports and other records under our control.

10. Your Rights

Subject to applicable law, you may have the right to:

• Access personal data we hold about you.

• Rectification of inaccurate or incomplete personal data.

• Erasure of your personal data in applicable circumstances.

• Restriction of certain processing activities.

• Objection to processing based on legitimate interests.

• Data portability where the relevant legal conditions apply.

• Withdrawal of consent at any time where processing is based on consent.

You also have the right to object at any time to the processing of your personal data for direct marketing purposes.

Withdrawing consent does not affect the lawfulness of processing carried out before withdrawal.

You may exercise these rights by contacting:

Socials@SystemsHeavy.com

We will respond to valid requests within the timeframes required by applicable data protection law.

11. Marketing Communications

If you provide optional marketing consent, Systems Heavy may contact you by email with relevant news, development updates, promotions, game announcements and potential playtesting opportunities.

Marketing consent is separate from participation in the survey and Prize Draw.

You can unsubscribe at any time using the unsubscribe instructions included in marketing emails or by contacting us directly.

Withdrawing marketing consent will not affect your eligibility for, or participation in, the Prize Draw.

We do not use Prize Draw contact information for marketing unless you have separately provided valid consent.

12. Security

We apply reasonable technical and organisational measures designed to protect personal data against unauthorised access, loss, alteration, disclosure or misuse.

These include limiting access to authorised personnel, using access-controlled services and separating identifiable contact information from research data where practicable.

Although we take appropriate precautions, no method of electronic transmission or storage can be guaranteed to be completely secure.

13. Automated Decision-Making

Winners of the Prize Draw will be selected randomly in accordance with the published Prize Draw Terms & Conditions.

Survey responses, gameplay performance and marketing preferences do not influence winner selection.

We do not use survey information for automated profiling or decisions producing legal or similarly significant effects on participants within the meaning of Article 22 GDPR.

14. Your Right to Complain

If you have concerns about how your personal data is handled, we encourage you to contact Systems Heavy using the details provided in this notice.

You also have the right to lodge a complaint with an appropriate data protection supervisory authority.

For participants in Berlin, this includes:

Berliner Beauftragte für Datenschutz und Informationsfreiheit

https://www.datenschutz-berlin.de/

You may also contact the supervisory authority in the EU/EEA country of your habitual residence or place of work, or where an alleged infringement occurred.

15. Changes to This Privacy Notice

Systems Heavy Inc. reserves the right to amend or update this Privacy Notice at any time.

Minor editorial, formatting or other non-material changes may be made without prior notice. The revised notice will be published with an updated effective date.

Where changes materially affect how we collect, use, share or otherwise process personal data, we will provide appropriate notification in accordance with applicable data protection law. Where required, this notification will be provided before the changes take effect, and additional consent will be obtained where legally necessary.

Changes to this Privacy Notice will not retrospectively diminish individuals' statutory data protection rights or expand the scope of consent previously provided.

16. Contact Information

For enquiries, privacy requests or concerns regarding the survey and Prize Draw:

Systems Heavy Inc.

8 The Green, STE B

Dover, Delaware 19901

United States

Email: Socials@SystemsHeavy.com

This notice applies specifically to the VCO: Victor Charlie One survey and associated Prize Draw at Games Ground Berlin 2026 and should be read alongside Systems Heavy Inc.'s general Privacy Policy and the applicable Prize Draw Terms & Conditions.

Prize Draw Terms & Conditions:

https://systemsheavy.com/legal/vco/gamesground2026/terms

Prize Draw Period: 5–8 November 2026.

Under the separate Prize Draw Terms & Conditions, selected winners will be notified within 60 days following the close of the Prize Draw, have 14 calendar days to respond and, where applicable, ordinarily receive prize dispatch within 90 days of confirmation and provision of necessary information. Experiential prizes may follow a separately arranged fulfilment schedule.

All rights reserved.