SEGA EUROPE LIMITED PRIVACY POLICY

Last Updated
February 2022

INTRODUCTION

SEGA Europe Limited, its subsidiaries and affiliates (together “SEGA”, individually a “SEGA Entity”) are committed to protecting the privacy and security of your personal data. SEGA collects different types of information from you when you use our mobile, online and downloadable products and services (together, the “Products“).

This Privacy Policy explains how we collect, use and protect your personal data when you use our Products or interact with us.

By using our Products you acknowledge that you have read and understood the terms of this Privacy Policy, including how we use your personal data.

The data controller is responsible for collecting and using your personal data.  To comply with data protection legislation, the data controller will be the SEGA Entity with whom you contract for a Product. See the ‘Your questions and how to contact us’ section of this Privacy Policy for more details.

We reserve the right to update this Privacy Policy from time to time by changing it as it applies to your use of any of our Products. We want you to enjoy using our Products and urge you to follow common sense whenever disclosing personal data – in our Products or elsewhere.

SUMMARY

Our Privacy Policy will help explain what information we collect, how we use it and what options you have in relation to it. The key points of our Privacy Policy are provided below, however you can also learn more by clicking the ‘show more’ link below.

1. INFORMATION WE COLLECT AND RECEIVE

We collect personal data about you and the devices you use to access and interact with us and our Products. We collect:

(a) Registration information: you give us when you sign up to access our Products
(b) Billing information: provided by you and/or third party stores
(c) Technical and device information: information from your mobile or computer device when you use our Products
(d) Feedback / surveys / user research: your questions, suggestions or views on our Products
(e) Third party information: information about your use of our Products that is shared with third party platforms and services connected with our Products
(f) Information from publicly available online sources: information about your use of our Products that is shared with third party platforms and services connected with our Products
(g) Information about your use of our Products: information we collect when you use our Products
(h) Competitions: information you provide to us when you participate in our competitions
(i) Social media plug-ins: information that is collected when you utilise third party social media plug-ins relating to our Products
(j) Anti-cheat and anti-hacking technologies: information that helps us to ensure our Products are used in a fair and lawful manner
(k) LiveOps software: information that is processed by third party LiveOps tools when you use our Products
(l) User Acquisition/Attribution and Core / Custom / Lookalike Audiences: information that is collected to help us acquire new users for our Products and to build Core, Custom and Lookalike Audiences

 

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2. OUR USE OF COLLECTED INFORMATION

Collected information may be used in the following ways:

(A) REGISTRATION INFORMATION:

(i)  to create your profile and so you can access our Products;

(ii)  to identify you when you sign-in;

(iii)  to give you access to your user preferences;

(iv) to contact you for your views on our Products;

(v)  to notify you of changes or updates to our Products; and

(vi)  for marketing purposes, based on your communication preferences.

(B) BILLING INFORMATION:

(i)  to verify your purchase of our Products and process any refunds;

(ii)  to reply to any queries and questions and to resolve problems;

(iii)  to carry out analysis and research to develop our Products; and

(iv)  to protect you and our Products by seeking to detect and prevent fraud or other acts in breach of our user agreements or policies relevant to our Products.

(C) TECHNICAL AND DEVICE INFORMATION:

(i)  to provide you with an optimal experience;

(ii)  to understand how you interact with our Products

(iii)  to provide Products you request;

(iv)  to measure and analyse the use and effectiveness of our Products;

(v)  to understand which of your devices are using our Products and playing our videogames;

(vi)   to provide safe and fair gaming environments;

(vii)  to customise and optimise the targeting of our advertising both within our Products and across our websites;

(viii)  to operate and improve our Products; and

(ix)   to fix errors.

(D) FEEDBACK / SURVEYS / USER RESEARCH:

(i)  to reply to your questions or queries;

(ii)   to record comments and information which you provide on our gaming forums; and

(iii) to conduct analysis and research to improve and develop our Products.

(E) THIRD PARTY INFORMATION:

(i)  to enable us to provide tailored offers to you;

(ii)   to facilitate sharing on social networks; and

(iii)    to facilitate your gameplay.

(F) INFORMATION FROM PUBLICLY AVAILABLE ONLINE SOURCES:

(i)   to understand the community sentiment about our Products.

(G) INFORMATION ABOUT YOUR USE OF OUR PRODUCTS:

(i)  to track the performance of our Products;

(ii)  to communicate with our platform operators and partners; and

(iii)  to improve our advertising and targeting systems.

(H) COMPETITIONS:

(i)   to verify your identity; and

(ii)  to distribute prizes to you.

(I) SOCIAL MEDIA PLUG-INS:

(i)  to allow you to easily share our content via social media platforms.

(J) ANTI-CHEAT AND ANTI-HACKING TECHNOLOGIES:

(i)  to detect illegal or malicious activity in our Products.

(K) LIVEOPS SOFTWARE:

(i)  to provide certain in-game features and functionality.

(L) USER ACQUISITION / ATTRIBUTION AND CORE / CUSTOM / LOOKALIKE AUDIENCES:

(i)to acquire new users for our Products, to measure the performance and effectiveness of our marketing campaigns and help us build Core, Custom and Lookalike Audiences for analytics and marketing purposes.

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3. WHEN WE SHARE INFORMATION

We may share the information we collect about you (subject to the necessary security, contractual and transfer safeguards).  These are some of the partners we may share your personal data with:

(a) SEGA companies within the wider SEGA group;

(b) Third party platform operators such as Valve who  operate the Steam digital download platform, Epic, Apple, Google Play, Sony PlayStation, Nintendo, Microsoft Xbox, and other partners who carry out various activities and services to support our Products (collectively, the “Platform Operators”);

(c) Marketing partners for marketing or promotions such as Mailchimp, based on your communication preferences;

(d) New owners or re-organised entities and their advisors in the event of a business restructure, sale, purchase or joint venture affecting our business; and

(e) Law enforcement agencies/authorities, when we are under a duty or are authorised by law for law enforcement purposes.

Your personal data may be transferred to other countries where SEGA or its service providers maintain operations. These countries may not have equivalent data protection laws to the country from where you access our Products, but we will ensure that we rely on appropriate safeguards.

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4. SECURITY AND DATA RETENTION

Your privacy is important to us and we place great importance on the steps we take, including technical and organisational measures to protect your information from unauthorised access and against unlawful processing, accidental loss, destruction and damage.

Your personal data will be kept by SEGA for the duration of your relationship with us and for as long as you use our Products and may be retained for a period after this time if it is necessary and relevant to our legitimate operations, our terms with you and in accordance with applicable laws.

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5. YOUR CHOICES AND RIGHTS

You have options and choices over how we use your personal data. You may be required to register or sign in to use or access some of our Products, and may need to provide personal data to create a user profile which is associated with your use of our Products.

If you wish to amend the personal data that you use to access our Products or would like us to correct, erase, restrict, object to, or move your personal data, you can make a support request, selecting ‘DATA REQUESTS’ from the drop down menu on our website. You can also contact us by post or phone using the details below. Please note that if you do not want us to process and/or access your personal data, you may be unable to use some of our Products.

By telephone on: +44 845 301 5502

By writing to us at:

SEGA Europe Limited
Customer Services
27 Great West Road
Brentford
Middlesex
TW8 9BW
United Kingdom

If you sign up to our marketing communications, you will be asked to confirm your communication preferences and will be given the opportunity to unsubscribe at any time.

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6. CHILDREN’S INFORMATION

Protecting the privacy of young children is especially important to SEGA. For that reason, SEGA does not knowingly collect or maintain personal data or non-personally identifiable information from users under 13 years of age, other than as permitted by law in support of our internal operations.

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7. CALIFORNIAN PRIVACY NOTICE

The Californian Consumer Privacy Act 2018 (the “CCPA”) and the Californian Shine the Light law provides Californian residents with certain rights regarding the processing of their personal data.

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8. YOUR QUESTIONS AND HOW TO CONTACT US

If you have any questions or comments about this Privacy Policy you can contact us.

If you have any questions or comments about this policy or our practices you can contact us by making a support request on our website:

By telephone on: +44 845 301 5502

By writing to us at:

SEGA Europe Limited
Customer Services
27 Great West Road
Brentford
Middlesex
TW8 9BW
United Kingdom

You can also contact our data protection officer at dpo@sega.co.uk.