SEGA CORPORATION PRIVACY POLICY

Last Updated
2024/06/17

Introduction

SEGA CORPORATION, its subsidiaries and affiliates (together “SEGA” or “SEGA Group”, individually a “SEGA Entity”) are committed to protecting the privacy and security of your personal information.  The term “personal information” used herein also includes “personal data” and equivalent terms, as such terms are defined under applicable laws. SEGA collects different types of information from you, including personal information, 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 information when you use our Products or interact with us. SEGA is responsible for collecting and using your personal information. See the “Your questions and how to contact us” section of this Privacy Policy for more details.

By using our Products, you acknowledge that you have read and understood the terms of this Privacy Policy, including how we use your personal information. 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 be follow common sense whenever disclosing personal information – in our Products or elsewhere.

The Products may contain links to third-party websites, plug-ins, features, or services. If you choose to use these sites or features, please note that we do not have control over the third parties that operate these websites and services and are not responsible for their content or privacy practices. We encourage you to read their privacy policies before using their websites or services or giving them your personal information.

SUMMARY

Our Privacy Policy will help explain what information we collect, how we use it and what options you have in relation to it.

We will only collect and process your personal information where we have a lawful basis in your country. As stated throughout this Privacy Policy, our lawful bases include consent (for example, where you have agreed to receive updates and marketing emails from SEGA), contract (where processing your personal information is necessary for the performance of a contract with you (e.g., to supply the Products you have requested)), compliance with our legal obligations, and our legitimate business interests in administering our business operations.

1. INFORMATION WE COLLECT AND RECEIVE

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

In connection with your visits and interactions with us through the Products, we may automatically collect information about you and the devices you use to access our Products and interact with us. We may also collect information about you from affiliates, unaffiliated third parties (such as log-in services, stores, social networks, business partners, service providers, and operators of gaming and app platforms who carry out various activities and services to support our Products (“Platform Operators”)), publicly available sources, and other account holders.

Please read further below for more details on the personal information we collect or receive from you.

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

(A) REGISTRATION INFORMATION

When you register or sign up to use our Products (or a SEGA account associated with our Products), or to register to participate in an event or program that is hosted, sponsored, organized and/or administered by SEGA, we may collect information about you, including your name, contact details, login and password information, username, age or date of birth, gender, communication and privacy preferences and additional information that you chose to provide. You may be required to register with your Platform Operator account ID to use certain features within our Products. We may also collect your contact information so that you can sign up to receive SEGA’s marketing communications.

It may be possible to sign up for our Products using third-party connection or log-in services such as your Facebook account. If you access the Products through a third party service, you may allow us to have access to and store certain information from your social network profile. This information may include your name, username, date of birth, contact details, profile picture, your “likes,” and your list of friends, depending on your settings on such services. If you do not wish to have this information disclosed, do not use a social networking connection to access the Products. For a description of how social networking sites handle your personal information, please refer to their privacy policies and terms of use.  Social networking companies have features that may permit you to modify your privacy settings.

If you register for or participate in an event that is hosted, sponsored, organized and/or administered by SEGA, we may receive information such as your name, email address, phone number, and other information related to your participating in the event or program, and in some cases video or audio footage of the event (such as to post a photo of the event when we have a lawful basis to do so), from those who interact with or express interest in SEGA or our Products.

(B) BILLING INFORMATION

We or our third-party payment processors may collect payment information such as credit or debit card details (including expiration dates) and other billing information such as your name and address. We may collect this information from you and/or third party stores that have been authorized to sell our Products.

(C) TECHNICAL AND DEVICE INFORMATION

When you access our Products, we may collect technical information from the devices you use to access our Products and interact with us, for example your location information when using your mobile device where you choose to share this with us. This includes identifying devices that are connected to the Internet, hardware settings, components of your devices, installed software, updates and plugins to facilitate the use of our Products. We may automatically collect information such as your operating system and the version of that operating system, IP address (the unique address which identifies your device on the internet from which we may derive general location information, like city and state), your browser type, browser language preferences, unique device identifiers, advertising identifiers, and information about the mobile network you use. We may also collect usage data, such as when, how often and how long you interact with our Products, websites and services, the specific features you use and pages you visit, error logs, other system activity, and pages or applications through or from which you access our Products.

We, and/or our service providers may use cookies and similar technologies (including but not limited to web beacons and tracking pixels; collectively, “cookies”), or collect data about your device(s) to understand how you navigate through and interact with our Products, to learn what content is popular, to enhance the Products and provide you with a more relevant and personalized experience, for authentication and advertising purposes, to save your communication and privacy preferences, and to collect certain usage, device and general location information as described above. We may also collect this kind of information when you interact with email messages or other communications we send you. Please note that if you delete or choose not to accept cookies from us, you may not be able to use certain features of our Products.

(D) FEEDBACK / SURVEYS / USER RESEARCH and product testing

We will collect personal information from the messages and reviews you post on our social channels and forums, or other platforms where you can sign up for a SEGA account associated with our Products, and when you contact us, for example with a question, problem or comment.

If you decide to participate in our surveys, you may be asked to provide personal information, such as your name, age, general location (country, region, prefecture, province, state, etc.), gender and e-mail address (and other information relevant to the survey, for instance information about your gaming platforms and habits).

From time to time, SEGA carries out user research or Product testing sessions to improve our Products and obtain feedback from our customers about our Products. When you participate in these sessions, we may ask you to provide your personal information including your name, address, age, general location (country, region, prefecture, province, state, etc.), gender and email address (and other information relevant to the testing session, for instance information about your gaming platforms and habits). In some cases, SEGA may also film and record these sessions with your permission.

(E) INFORMATION FROM PUBLICLY AVAILABLE ONLINE SOURCES

We may collect and analyze information that you have made publicly available on the internet or through third party platforms such as Facebook, X (formerly Twitter), Reddit, and other public forums. The data that SEGA collects may include a Facebook comment, a post on X (formerly Twitter), or a post on a public forum about SEGA or our Products.

(F) INFORMATION ABOUT YOUR USE OF OUR PRODUCTS

We collect information from your web browser about the way you use our Products. We may also collect analytical information about your interaction with SEGA or our Products from the notifications or messages you post or send online as well as what you search for, look at and engage with. Information obtained from social features used within our Products, such as in-game communications, forums, and chat functionality, may be stored, copied or used by SEGA or our third party service providers.

When you visit or use our Products we collect, process and combine information about your use of those Products, such as your IP address, Platform Operator account information (e.g. the pseudonymized user ID associated with your Xbox or Steam account), hardware and software information, and aggregate gameplay data, usage data (including in some cases video recordings, such as for usage data of physical arcade machines), and purchase histories.

We may collect information about you and your use of Products, including sales data and gameplay data related to your interactions with our Products, including player performance statistics, in-game actions, character options, and other similar in-game data. We may also receive such information from Platform Operators.

Platform Operators (such as Valve for the Steam digital download platform) may provide us with information (such as pseudonymized Steam IDs) to help optimize our offerings to you and to help us understand how you are using our Products.

(G)  INFORMATION ABOUT YOUR PARTICIPATION IN contests 

When you participate in a contest organized by SEGA, we may ask you to provide certain personal information, such as your name, email address, country of origin and other identifiers, such as the User ID for the Platform Operator that you use to access our Products (e.g. Steam ID). You may also be required to submit other information in relation to the contest, such as a photograph or video of yourself (for example, where this forms part of the entry requirements of a contest).

Winners may be required to provide their address for the purpose of SEGA delivering the prizes, or in some cases to register with authorized third-party partners that issue prizes on our behalf.

The contest you participate in will have its own terms and conditions, which will set out the specific requirements in more detail.

(H) INFORMATION FROM ANTI-CHEAT AND ANTI-HACKING TECHNOLOGIES 

SEGA strives to ensure that anyone who interacts with our Products, or participates in our competitions and tournaments, does so in a fair and lawful manner. SEGA may utilize anti-cheat and/or anti-hacking technologies to collect certain personal identifiers relating to your use of our Products.

(I) INFORMATION FROM LIVEOPS SOFTWARE 

Our Products may include third party LiveOps Software which helps us to provide in-game features that are core to your gameplay experience. For example, the software may enable us to offer multiplayer modes, leader boards, in-game rewards and more. The software may also allow SEGA to collect data analytics relating to your use of the Product.  If you play a Product that uses LiveOps Software, that third party software may collect certain personal information about you as required by that service. The third-party LiveOps Software may process and store this personal information in accordance with the third party’s privacy policy. The software may also allow SEGA to collect data analytics relating to your use of the Product.

Examples of data that may be collected include a unique user account ID, IP address, how often you play, your progress through the game and information about your gaming device.

2. OUR USE OF COLLECTED INFORMATION

We may use your information in the following ways:

(A) REGISTRATION INFORMATION:

(i)  to create your profile, enable access to our Products, or to enable you to participate in an event that is hosted, sponsored, organized and/or administered by SEGA;

(ii)  to identify you when you sign in;

(iii)  to give you access to your communications and privacy 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 and privacy 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 business; 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 analyze 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 customize and optimize 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 and product testing:

(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) INFORMATION FROM PUBLICLY AVAILABLE ONLINE SOURCES:

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

(F) INFORMATION ABOUT YOUR USE OF OUR PRODUCTS:

(i)  to track the performance of, and to improve, our Products;

(ii)  to communicate with Platform Operators and our other partners; and

(iii)  to improve our advertising and targeting systems.

(G) INFORMATION ABOUT YOUR PARTICIPATION IN Contests: 

(i)  to verify your identity;

(ii)  to distribute prizes to you; and

(iii)  to carry out publicity activities relating to the contest.

(H) INFORMATION FROM ANTI-CHEAT AND ANTI-HACKING TECHNOLOGIES:

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

(I) INFORMATION FROM LIVEOPS SOFTWARE: 

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

We may combine the information we collect through our Products with information we collect automatically or receive from other sources identified in this Policy and use such combined information in accordance with this Privacy Policy. Your browsing activity may be tracked across different websites and different devices or apps. For example, we may attempt to match your browsing activity on your mobile device with your browsing activity on your laptop. To do this, our technology partners may disclose data, such as your browsing patterns, geo-location and device identifiers, and match the information of the browser and devices that appear to be used by the same person.

We may also aggregate and/or de-identify information collected through our Products in such a way that the information cannot reasonably be linked to you or your device. We may use de-identified or aggregated data for any purpose, including for research and marketing purposes, and we may disclose such data to any third parties, including advertisers, promotional partners, sponsors, and others.

Please read further below for more details on how we use the information we collect and/or receive from you.

We use the personal information we collect for the following purposes:

(A) REGISTRATION INFORMATION

Your registration information enables us to create your profile, provide you with access to our Products, supply the Products, facilitate your participation in an event that is hosted, sponsored, organized and/or administered by SEGA, and to give you access to your user preferences. This is necessary for the purpose of performing the contract we have with you. It helps us to authenticate your access, to contact you for your views and to notify you of important changes or updates to our Products.

In some cases, you may be able to sign up for our Products using third party services such as your Facebook account. In such cases, that provider may provide your personal information to us, subject to their privacy policy and the privacy settings of your account with them.  This may also enable the provider and us to link your activities with your personal registration information at their site, and may include notifying your friends about your activities while using our Products. If you sign up via third party services, you should visit the third party website and review their privacy policy and your registration profile or account to understand how your data is processed by them and to find out what your options are.

When we have your consent and in accordance with your stated communication preferences, we may also contact you for marketing purposes to let you know by email, telephone, mobile or in-app messaging about our other Products and services. We provide further information below in the “Marketing Communications” section.

(B) BILLING INFORMATION

This information will enable us to facilitate and verify your purchases, including with third party stores and Platform Operators, and to contact you to assist with resolving any problems with your purchases and to process any refund payments to you.

We will also use and analyze information on transactions on your account by data matching or statistical analysis so that we can administer, support, improve and develop our business and to help us detect and prevent fraud, or other illegal activities, or acts prohibited by our terms of service or any policies applicable to our Products.

(C) TECHNICAL AND DEVICE INFORMATION

We use internet log files to monitor traffic on our Products, resolve technical problems and to detect and prevent fraud.

We may use these technologies to provide us with information, such as when an email is opened, or to develop statistics on the effectiveness of advertising or marketing on our websites. In some cases, working with third-party partners, we use this information to send you ads for our Products based on your interests.

We also use technical and device information to operate and improve our Products, enable online matchmaking, facilitate sharing, measure our effectiveness, set up and maintain accounts, identify and fix errors and to help keep online content fair and safe and to resolve related disputes.

(D) FEEDBACK / SURVEYS / USER RESEARCH and product testing

We use your feedback to reply to your questions or queries, to provide customer support and resolve problems relating to any of our Products. We will also publish reviews about our Products that you submit to us for this purpose and will conduct analysis of feedback for the purpose of improving and developing our Products.  In some cases, SEGA may also film and record user research sessions with your permission so that we can observe your playing habits and record your feedback.

SEGA uses the information collected during surveys and user research sessions to help us to tailor and improve our Products.

SEGA may share data from user research sessions with certain third-party partners when there is a legitimate business requirement to do so. In such circumstances, your data will always be fully anonymized before it is shared.

(E) INFORMATION FROM PUBLICLY AVAILABLE ONLINE SOURCES

We will use and analyze this data to learn about how you use our Products, how you engage with our marketing campaigns and to gain an understanding of community sentiment about our Products.  We may use third party analytics providers who collect this data on our behalf.

(F) INFORMATION ABOUT YOUR USE OF OUR PRODUCTS 

This information enables us to track the performance of and improve our Products, develop new Products, optimize your experience, and communicate with Platform Operators and our other partners. It also enables us to better understand our users and improve our advertising, targeting and measurement systems.

We analyze information about how you engage with our Products to understand how our Products are used and to provide you with an optimal gaming experience, such as by rolling out performance-optimizing software updates for our Products.  We use this data in order to analyze and produce statistics relating to the habits, usage patterns and demographics of users as a group or as individuals.  This allows us to deliver you customized content, helps us understand the features of our Products that appeal to you and allows us to manage advertising and improve and operate our business.

We may also choose to provide functionality within our Products which enables you to upload gameplay footage to YouTube. In such case, if you choose to use this feature, we will receive and store an authentication token from Google so that the feature will operate properly.  The use of this functionality is governed by YouTube’s Terms of Service: https://www.youtube.com/static?template=terms.  Further information about the protection of your privacy can be found in Google’s privacy policy: https://policies.google.com/privacy?hl=en-US. You can also view and modify your permissions via Google’s security settings: https://myaccount.google.com/permissions.

(G) INFORMATION ABOUT YOUR PARTICIPATION IN Contests 

SEGA collects and processes this data for the purposes of running and monitoring a contest, as well as for carrying out publicity activities relating to the contest.

(H) INFORMATION FROM ANTI-CHEAT AND ANTI-HACKING TECHNOLOGIES 

SEGA may utilize anti-cheat and/or anti-hacking technologies to help us detect an illegal or malicious activity and to take the appropriate actions if such activity is detected.

The anti-cheat/hacking technologies within your Product may require you to download certain data to your device. If you disable or otherwise tamper with these technologies, the Product may not operate properly and you may be in breach of the applicable end user license agreement or terms of service.

(I) INFORMATION FROM LIVEOPS SOFTWARE 

Our Products may include third party LiveOps Software which helps us to provide in-game features that are core to your gameplay experience. For example, the software may enable us to offer multiplayer modes, leader boards, in-game rewards and more.

3. ONLINE AND MOBILE APP ADVERTISING

ONLINE ADVERTISING ON OUR WEBSITES AND NON-SEGA PROPERTIES

We may allow third-party advertising technologies (e.g., ad networks and ad servers such as Google’s ad services, and others) on our Products that use cookies to deliver relevant and targeted content and advertising to you on the Products and other websites you visit and applications you use. The ads may be based on various factors such as the content of the page you are visiting, information you provide, your searches, demographic data, and other information we collect about you. These ads may be based on your current activity or your activity over time and across other websites and online services and may be tailored to your interests. In accordance with applicable law in your jurisdiction (such as California), we do not share your age or gender with third parties to enable them to deliver targeted advertising to you based on your age or gender in our mobile apps, except that we may inform third parties if we know that you are under the age of consent (see “Children’s Information” section below).

Information on Cookies: a cookie is a small file that can be placed on your device that allows us to recognize and remember you. When you visit our websites, we may collect information automatically through cookies. Cookies are essential to provide you with the best services possible and are used to improve those services. In addition, cookies are used to remember and recognize your preferences, so that we can provide a better personalized experience for you, and to help prevent fraudulent activity, improve security, and deliver content. We may use Google Analytics Demographics and Interest Reporting feature to collect certain information, including, without limitation, age, gender, and interests. You can manage the use of cookies, including advertising cookies, and disable the sharing of data with partners for advertising purposes, by changing your personal settings on your Ad Settings page and/or downloading and installing Google’s Opt-out Browser Add-on for your web browser. You can also customize advertisements displayed through Google Display Network by changing your personal settings in your Ad Settings page. Your Ad Settings page can be accessed through your personal Google account. In some cases, you can turn off advertising cookies on a cookie-by-cookie basis. Please note that the use of cookies or other tracking technologies that may be placed on devices you use to access our Products by unaffiliated third parties is governed by the privacy policies of those third parties. If you are interested in more information about tailored browser advertising and how you can generally control cookies from being put on your devices to deliver tailored advertising, you may visit the Network Advertising Initiative’s Consumer Opt-Out link or the Digital Advertising Alliance’s Consumer Opt-Out link to access information about how you can opt out of tailored advertising from companies that participate in those programs.

For additional ways to opt-out of targeted advertising activities under applicable laws, see the “Your Choices and Rights” section below.

Please note that these opt-outs apply per browser and per device, so you will have to opt out for each device—and each browser on each device—through which you access our Products. In addition, the opt-outs do not apply to advertisements in mobile applications. See the “Mobile App and In-Product Advertising” section below to learn how to opt out of mobile app advertising.

MOBILE APP AND IN-PRODUCT ADVERTISING

You may also receive tailored in-app advertisements when using our mobile apps. We may use third-party service providers to deliver ads on mobile apps or for mobile app analytics.  Each operating system (for example iOS for Apple phones, Android for Android devices, and Windows for Microsoft devices) provides its own instructions on how to express certain choices regarding the delivery of tailored in-application advertisements. Because we do not control how the applicable Platform Operator enables these choices receiving personalized in-application advertisements, you should review the support materials and/or the device settings for the respective operating systems for information on opting out of tailored in-application advertisements. In accordance with applicable law in your jurisdiction (such as California), we do not share your age or gender with third parties to enable them to deliver targeted advertising to you based on your age or gender in our mobile apps, except that we may inform third parties if we know that you are under the age of consent (see “Children’s Information” section below).

Further information about the protection of your privacy can be found in the relevant third party entity’s privacy policy.

NOTICE CONCERNING DO NOT TRACK

Do Not Track (“DNT”) is a privacy preference that is available in certain web browsers. We do not currently recognize or respond to browser-initiated DNT signals. Please note that Do Not Track is a different privacy mechanism than the user “preference signal” referenced in the “Your Choices and Rights” section below, which is a legally recognized browser-based control that indicates whether you would like to opt out of processing of your personal information for certain purposes, such as the “sale” or “sharing” of your information or the disclosure of your personal information for targeted advertising purposes, under applicable laws.

4. HOW WE DISCLOSE INFORMATION

We or our service providers may disclose the information we collect about you (subject to legally required security, contractual and transfer safeguards).  These are some of the partners we may disclose your personal information to:

(a) SEGA companies within the wider SEGA Group;

(b) Service providers;

(c) Platform Operators;

(d) Other unaffiliated third parties, including third parties we collaborate with in connection with integration, co-marketing, and certain other coordinated efforts as well as third parties whose offers we believe you may value (e.g., advertising partners for the service of advertisements within our Products);

(e) Others at your direction and with your consent;

(f) New or potentially new owners or re-organized entities and their advisors in the event of a business restructure, transfer, merger, dissolution sale, purchase, joint venture, or similar event involving our business (including in contemplation of such transactions); and

(g) Law enforcement agencies/authorities or others, when we are under a duty or are authorized by law for law enforcement purposes or to enforce relevant terms of service and any other agreement or to protect our rights or the rights of third parties.

In delivering our Products to you, we may disclose your personal information to:

• Companies within the SEGA Group (which means SEGA Entities which are our affiliated companies, our ultimate holding company and its subsidiaries and affiliates) who act for us for the purposes set out in this policy.
• Third party service providers in order to undertake various activities or services on our behalf in supporting our Products. This includes payment processing providers facilitating credit and payment card transactions, website and application support and hosting providers for online videogame services and software downloads, and providers of promotional, digital advertising or other communications.
• Other unaffiliated third parties such third parties we collaborate with in connection with integration, co-marketing and certain other coordinated efforts and third parties whose offers we believe you may value.
• Others at your direction and with your consent or in conjunction with your participation in contests.
• In the event of sale (of some or all of our assets), transfer, merger, reorganization, dissolution, or similar event involving our business (including in contemplation of such transactions), your personal information may be among the transferred business assets. If such transfer is subject to any mandatory restrictions under applicable laws, we will comply with those restrictions.
• We may use the information that you provide if we are under a duty to disclose your personal information in order to comply with (and/or where we believe we are under a duty to comply with) any legal obligation; or if we believe in good faith that disclosure is reasonably necessary to: (i) enforce the relevant terms of service and any other agreement; (ii) respond to claims that any content violates the rights of third parties; or (iii) protect the rights, property, or personal safety of SEGA, users of our Products, or others. This includes exchanging information with other companies and organizations for fraud protection, spam/malware prevention, and similar purposes, such as credit agencies, law enforcement or government bodies or the courts in connection with a criminal investigation or suspected illegal activity.

5. SECURITY AND DATA RETENTION

Your privacy is important to us and we place great importance on the steps we take, including physical, technical and organizational measures, to protect your personal information from unauthorized access and against unlawful processing, accidental loss, destruction and damage. However, no method of transmission over the internet, and no means of electronic or physical storage, is absolutely secure. We cannot guarantee the security of your personal information transmitted to, through, or on our Products and that any such transmission is at your own risk.

When you have chosen a password which allows you to access any of our Products, you are responsible for keeping this password confidential. We advise you not to share your password with anyone. We will not be liable for any unauthorized transactions entered into using your personal information, including but not limited to your username, and/or password. If you suspect unauthorized access, you should immediately change to a strong password.

We will retain your personal information for the duration of your use or access to our Products and may retain it for a period after this time as necessary and relevant to our legitimate operations (e.g., to resolve disputes), our terms with you, and in accordance with applicable laws and obligations. This may include retention necessary to meet our tax reporting requirements as well as time required to fulfil transactions you have requested, enforce any obligations in our agreements, any game “sun-setting” requirements or to identify, issue or resolve legal proceedings or disputes, fraud prevention, and related security purposes. We retain information only as long as considered necessary by taking into account the amount, nature and sensitivity of the information, the potential risk of harm from unauthorized use or disclosure of the information, the purposes for which we process the information, applicable legal requirements, and our general business operations.

We may retain a record of your stated objection to the processing of your data, including in respect of an objection to receiving marketing communications, for the sole purpose of ensuring that we can continue to respect your wishes to not contact you further, during the term of your objection.

We will take appropriate steps to seek to destroy or permanently de-identify personal information at the point this information is no longer needed by us for our business or legal purposes.  We may retain cached or archived copies of your personal information. For more information about exercising your rights with respect to our data processing activities, or if you no longer wish to use our Products, see details below about your choices and rights.

6. YOUR CHOICES AND RIGHTS

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

If you wish to amend the personal information that you use to access our Products; object to our processing of your personal information; or would like us to correct, erase, restrict, or move your personal information, you can contact us using the details below. Please note that if you do not want us to process and/or access your personal information, you may be unable to use some of our Products.

RIGHTS REGARDING YOUR INFORMATION

We provide you with tools to access and update specific information relating to your use of our Products at any time. If you need to sign in to access certain Products, you can update and amend your key contact information directly.

Depending on your jurisdiction, you may have the right to make certain requests regarding your personal information, as listed below.

You have the right to ask us to:

• Inform you about the categories of personal information we collect or disclose about you; the categories of sources of such information; the business or commercial purpose for collecting your personal information; and the categories of third parties with whom we disclose personal information.
• Provide you access to and/or a copy of certain personal information we hold about you.
• Correct or update personal information we hold about you.
• Delete certain personal information we have about you.
• Provide you with information about the financial incentives that we offer to you, if any.
• Opt you out of the processing of your personal information for purposes of profiling in furtherance of decisions that produce legal or similarly significant effects, if applicable.

You may also have the right to opt out of “sales” of your personal information and “sharing/use of your personal information for targeted advertising” as described below.

As provided in applicable laws, you also have the right to not be discriminated against for exercising your rights. Please note that certain information may be exempt from such requests under applicable laws. For example, we need to retain certain information in order to provide our services to you. We also need to take reasonable steps to verify your identity before responding to a request, which may include, at a minimum (depending on the sensitivity of the information you are requesting and the type of request you are making), verifying your name and email address. Depending on your jurisdiction, you may be permitted to designate an authorized agent to submit certain requests on your behalf. In order for an authorized agent to be verified, such individual may be requested to provide proof of your signed, written and informed permission to make such requests or a power of attorney. We may also follow up with you to verify your identity before processing the authorized agent’s request. If you would like further information regarding your legal rights or would like to exercise any of them, please email us at dataprivacy@sega.com.

Depending on applicable laws, you may have the right to appeal our decision to deny your request, if applicable. To exercise such an appeal right, please contact us via the communication method(s) as noted in our decision.

In addition, if you believe that we have not responded to your privacy-related inquiry or your inquiry has not been satisfactorily addressed, please contact us using the contact details below or at dataprivacy@sega.com.

For users in the EEA/UK – If you remain unhappy with a response you receive, you can also refer the matter to your data protection supervisory authority (see http://ec.europa.eu/justice/data-protection/bodies/authorities/index_en.htm).

MARKETING COMMUNICATIONS

You may unsubscribe from our marketing communications via the unsubscribe option in the communication you receive, or by changing your communication settings where available. Please note that it may take us some time, consistent with our legal obligations, to process your request. Even if you opt out from receiving marketing messages from us, you may continue to receive administrative messages from us, such as purchase confirmations, updates to our policies and practices, or other communications regarding our relationship or transactions with you. Please note that we will retain a record of the user information when you unsubscribe from our marketing information for the legitimate purpose of ensuring that we do not contact you further in this way, during the period of your objection, if relevant.

NOTICE OF RIGHT TO OPT OUT OF SALES OF PERSONAL INFORMATION AND PROCESSING/SHARING OF PERSONAL INFORMATION FOR TARGETED ADVERTISING PURPOSES

Depending on your jurisdiction, you may also have the right to opt out of “sales” of your personal information and “sharing/use of your personal information for targeted advertising.”

As explained in the “How We Disclose Information” section above, we sometimes disclose information to unaffiliated third parties we collaborate with or that provide offers that we think may be of value to you. This disclosure of information may be considered a “sale” or “sharing” under applicable laws.

We may also provide personal information to third-party advertising providers for targeted advertising purposes, so that we can provide you with more relevant and tailored ads regarding our Products, or use analytics partners to assist us in analyzing use of our Products and our user/customer base. The disclosure of your personal information to these third parties to assist us in providing these services may be considered a “sale” of personal information under applicable laws, or, the processing/sharing of personal information for targeted advertising purposes.

If you would like to opt out of our online disclosure of your personal information for purposes that could be considered “sales” for those third parties’ own commercial purposes, or “sharing” for purposes of targeted advertising, please go to the respective Sega property (e.g., sega.com, sega.co.uk, sega.jp, or the specific website for a SEGA game or app) and click on the “Your Privacy Choices” or related link in the footer of the website, or utilize the website popup (please note that opt-out method may vary depending on the website). You must make this choice on each site on each browser/device you use to access the services. You must also renew this choice if you clear your cookies or your browser is set to do that. You may also submit a request to opt out of the use of your email address and other personal information related to that email address for targeted advertising purposes by emailing us at dataprivacy@sega.com.

Please note that if you have a legally-recognized browser-based opt out preference signal turned on via your device browser, we recognize such preference as required by applicable laws.

MOBILE DEVICES

We may send you push notifications through our mobile applications. You may at any time opt out from receiving these types of communications by changing the settings on your mobile device.

7. NOTICE OF FINANCIAL INCENTIVES

We may offer opportunities to receive certain services or benefits (for example, money, virtual or tangible items, or entries into contests) by signing up for communications, participating in surveys or research sessions, or conducting other similar activities, which may require the provision of personal information, such as registering for an account and answering surveys or providing additional feedback or information. Such opportunities could be considered a financial incentive under applicable laws (each, an “Incentive Program”). Your participation in Incentive Programs is purely voluntary. When you participate in an Incentive Program, you agree to the terms of that Incentive Program, and may revoke your participation depending on the Incentive Program.

8. CHILDREN’S INFORMATION

Protecting the privacy of young children is especially important to SEGA. For that reason, SEGA does not knowingly collect, maintain, sell or share personal information or non-personally identifiable information from underage users other than as permitted by law. SEGA may identify underage users to third-party advertisers to ensure that third-party advertisers (i) do not collect personal information or non-personally identifiable information about those underage users and (ii) do not show age-inappropriate ads to those underage users.

In this Privacy Policy, any reference to underage users refers to those under the age of consent to the processing of personal information in their country of residence. For example, please see below for a non-exhaustive regional list of the age of consent for our privacy purposes as of the effective date of this Privacy Policy:

• Croatia, Germany, Hungary, Ireland, Luxembourg, Malta, Netherlands, Poland, Romania, Slovakia – 16 or under
• Czech Republic, France, Greece, Slovenia – 15 or under
• Austria, Bulgaria, Cyprus, Italy, Lithuania, Spain – 14 or under
• United States, United Kingdom and any EU countries not listed above – 13 or under

If SEGA learns that personal information of underage users has been collected  unlawfully, SEGA will take reasonable steps to remove such information. If you believe that we may have unintentionally collected personal information about your child who is underage, you may contact us using the details provided below.

9. CALIFORNIA PRIVACY NOTICE

This section supplements our Privacy Policy with additional information for California residents about our personal information collection and use practices as required by the California Consumer Privacy Act 2018, as amended by the California Privacy Rights Act of 2020 (the “CCPA”), Privacy Rights for California Minors in a Digital World, and the California Shine the Light, and provides information about California residents’ rights under those laws. In this section, the terms “personal information” and “sensitive personal information” have the meaning set forth in the CCPA.

The following chart provides information about our practices in the 12 months leading up to the effective date of this Privacy Policy in relation to the categories of personal information that we have collected from California residents generally, the purposes for which we use the information, and the categories of third parties to whom we disclose the information for business and operational purposes.

SALE AND SHARING OF PERSONAL INFORMATION 

As explained in the “How We Disclose Information” section above, we may disclose information to third parties we collaborate with or that provide offers that we think may be of value to you. This disclosure of information may be considered a “sale” or “sharing” under the CCPA. We may also provide personal information to third-party advertising providers for targeted advertising purposes, so that we can provide you with more relevant and tailored ads regarding our Products, or use analytics partners to assist us in analyzing the use of our Products and our user/customer base. The disclosure of your personal information to these third parties to assist us in providing these services may be considered a “sale” of personal information under the CCPA, or, the “sharing” of your personal information for purposes of “cross-context behavioral advertising.”

The following chart lists the categories of personal information we have sold or shared over the last 12 months and the categories of third parties to which we have sold or shared such personal information:

If you would like to opt out of our online disclosure of your personal information for purposes that could be considered “sales” for those third parties’ own commercial purposes, or “sharing” for purposes of targeted advertising, please go to the respective Sega property (e.g., sega.com, sega.co.uk, sega.jp, or the specific website for a SEGA game or app) and click on the “Your Privacy Choices” or related link in the footer of the website, or utilize the website popup (please note that opt-out method may vary depending on the website). You must make this choice on each site on each browser/device you use to access the services. You may also need to renew this choice if you clear your cookies or your browser is set to do that. You may also submit a request to opt out of the use of your email address and other personal information related to that email address for targeted advertising purposes by emailing us at dataprivacy@sega.com.

Depending on your jurisdiction, you may be permitted to designate an authorized agent to submit such requests on your behalf. Please note that we do not knowingly sell the personal information of children under 16 years of age without legally-required affirmative authorization.

Please note that if you have a legally-recognized browser-based opt out preference signal turned on via your device browser, we recognize such preference as required by applicable laws.

OTHER CALIFORNIA RIGHTS

California Civil Code Section 1798.83 (“Shine the Light”) permits our customers who are California residents to request, once per calendar year, the following information from us:  (i) a list of the kinds of personal information that we have disclosed to third parties for direct marketing purposes during the preceding calendar year; and (ii) the names and addresses of all of the third parties that received personal information from us for direct marketing purposes during the preceding calendar year. For inquiries regarding our disclosure policy, please contact us by emailing dataprivacy@sega.com. Requests must include “Shine the Light Rights Request” in the first line of the description and include your name, street address, city, state, and ZIP code.

California Business and Professions Code Section 22581 (“California Privacy Rights for Minor Users”) permits you, if you are a California resident under the age of 18, to view, correct or remove information provided by you or publicly posted by you. For inquiries regarding our disclosure policy, please contact us by emailing dataprivacy@sega.com. Requests must include “California Privacy Rights for Minor Users Request” in the first line of the description and include your name, street address, city, state, and ZIP code.

10. NEVADA RESIDENTS

Under Nevada law, certain Nevada residents may opt out of the “sale” of “covered information” (as such term is defined under Nevada law). We do not engage in such activity as of the effective date of this Privacy Policy.

11. INTERNATIONAL USERS

Personal information may, in accordance with applicable laws, be transferred to countries other than your country of residence where SEGA or its service providers or trusted business partners maintain operations, including the United States. These countries may not have equivalent data protection laws to the country from where you access our Products or, in the case of transfers subject to European law, may not be subject to an adequacy decision by the European Commission (EC).   An adequacy decision is a decision taken by the EC establishing that a third country provides a comparable level of protection of personal information to that in the EU, through its domestic law or its international commitments. Such third parties may be engaged in, among other things, the provision of our Products to you, the processing of transactions, and/or the provision of support services. By providing us with your personal information, you acknowledge any such transfer, storage, or use by such third parties.

Where SEGA transfers personal information it will seek to take account of any applicable legal obligations relevant to personal information transfers.  In the case of transfers of personal information out of the European Economic Area,  it will, in the absence of an EC adequacy decision for  the destination country, seek to rely on appropriate safeguards such as the EC approved standard contractual clauses relevant to personal information transfers between data controllers or between a data controller and a data processor (see https://commission.europa.eu/law/law-topic/data-protection/international-dimension-data-protection/standard-contractual-clauses-scc_en).

12. MOBILE APPLICATIONS

Several of our mobile products may serve advertising, and some of our partners may collect data directly from your device. Depending on your region and device, you may have choices regarding our partners’ access to certain data like your device ID and device geo-location data.

Certain Mobile Products may utilize third party advertising partners that serve advertisements (“Third Party Advertisers”), which may include behavioral, location or interest based advertising (“Interest Based Advertising”) within our Products. These Third Party Advertisers may use technology to serve the advertisements and link them directly with our Products, and they may automatically receive your device ID, IP address or geo-location data (limited to country/region) when this happens.

Please note that if you opt out of certain Interest Based Advertising, you may continue to receive contextual ads based on other non-personal information, such as ads related to the content of the Product you are using.

OPT-OUT FOR LOCATION DATA 

Certain Third Party Advertisers in Products may collect (with your permission) precise location data, or street-level location information, about you (“Precise Location Data”). Your mobile device may allow you to limit access to your device IDs and device geo-location data (including opt out of the collection of Precise Location Data such as by Third Party Advertisers) through the settings on your device. Please note that your mobile device will not share location information without your permission.

13. INFORMATION FROM SUPPLIERS, VENDORS, BUSINESS PARTNERS, AND SIMILAR BUSINESSES

Contact and Business Information. If you are a company or other organization that we engage with, or a representative of the foregoing, we may collect your name, phone number, email address, and postal address, government identifier, and business name, industry, locations, other information related to your employer, and any other information you choose to provide us, including through third-party portals and platforms.

Financial and Transactional Information. If we need to make payments to you or receive payments from you, we may collect financial account and related transactional information.

Communications. If you contact us, we may receive information such as your name, email address, and phone number. We also will receive the contents of any communications you have with us. This might include requests, questions, and/or issues regarding our Products, services we provide to each other, an account you hold with us, or other topics you might raise.

Events and Programs. If you register for or participate in an event or program that we host, sponsor, organize, administer, or attend, we may receive information such as your name, email address, phone number, and other information related to your attendance at the event or program from those who interact with or express interested in SEGA or our Products.

Surveys, Promotions, and Contests. If you decide to participate in any surveys, promotions, or contests, you may provide certain information, such as basic contact information and other information relevant to the survey, promotion, or contest.

14. LINKS TO OTHER SITES

The Products may contain links to a third-party website, plug-in, feature, or service. If you choose to use these sites or features, please note that we do not have control over the third parties that operate these websites and services and are not responsible for their content or privacy practices. We encourage you to read their privacy policies before using their websites or services or giving them your personal information.

15. CHANGES TO THIS PRIVACY POLICY

We may update this Privacy Policy from time to time in our sole discretion. You can know if the Privacy Policy has changed since the last time you reviewed it by checking the “Last Updated” date at the top of this page. We encourage you to look for updates and changes to this Privacy Policy periodically. If we make a material change to this Privacy Policy, we will endeavor to notify you through the Products, by email, and/or by other legally permissible communication as required by applicable laws. Your continued use of the Products after any changes to this Privacy Policy are in effect constitutes your acceptance of revisions to the Privacy Policy.

16. YOUR QUESTIONS AND HOW TO CONTACT US

If you have any questions or comments about this Privacy Policy or our practices, you can contact us: