SEGA Games Co., Ltd.

Mobile Application Privacy Policy

Effective Date – July 24, 2018

Introduction

SEGA Games Co., Ltd. (“SEGA”, “we”, “us” or “our”) is committed to protecting the privacy and security of your personal information. SEGA collects different types of information from you when you use our mobile, online and downloadable products and services (“Products”).

This Privacy Policy explains how we collect, use and protect your personal information when you use our Products.

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.

SEGA is the data controller of your personal information for purposes of the EU General Data Protection Regulation (“GDPR”; EU2016/679). See ‘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 the Products. The date of the current SEGA Privacy Policy is the Effective Date set out above. We want you to enjoy using our Products and urge you to follow common sense whenever disclosing personal information – 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 simply following the link below or by continuing to scroll down:

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:

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2. Our use of collected information

Collected information may be used in the following ways:

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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 information with:

(a) SEGA companies within the wider SEGA group.

(b) Third party service providers who need access to such information to carry out work on our behalf (e.g. website hosting services, information storage).

(c) Platform operators such as Valve who operate the Steam digital download platform, Apple, Google Play and other partners who carry out various activities and services to support our Products.

(d) Advertising partners for the service of advertisements within our Products.

(e) Marketing partners for marketing or promotions, based on your communication preferences.

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

(g) Where we are under a duty, are authorized by law or for law enforcement purposes.

Personal information that we collect from you is usually transferred, stored and processed in Japan. Personal information 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 the Products.

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4. Security and data retention

Your privacy is important to us and we take reasonable technical and organizational measures to protect your information from unauthorized access and against unlawful processing, accidental loss, destruction and damage. Your personal information 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 information. 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. Where you are required to sign in to use or access our Products, you can also manage and amend the personal information that you provide to us. In addition you can also contact us using the details below.

SEGA Games Co., Ltd.
Attn.: Contact for Personal Information
Osaki Garden Tower
1-1-1 Nishi-Shinagawa
Shinagawa-ku, Tokyo 141-0033
Japan
Email: sgcsupport@sega.com

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

You can contact us directly with requests to correct, erase, restrict, object to, or move your personal information. If you do not want us to process and/or access your personal information, you may be unable to use some of our Products.

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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 information or non-personally identifiable information from users under 13 years of age or other applicable age of consent, other than as permitted by law in support of our internal operations and/or for our legitimate interests.

Learn more

7. Your questions and how to contact us

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

Contact details


More information

1. Information we collect

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

When you register or sign up to use our Products we collect information about you including your name, contact details, age, gender, personal preferences and additional information that you chose to provide. We may also collect your contact information so that you can sign-up to receive SEGA’s marketing communications. As part of any required sign in to use our Products, we will verify the information that you use to log in.

You can also choose to sign-up for our Products using third party services such as your Facebook, Google, Twitter or Instagram (“Social Network”) account in which case the Social Network may ask you for your permission to provide certain personal information such as your username, date of birth and contact details. The Social Network may share this personal information with us subject to the Social Network’s privacy policy and the privacy settings of your Social Network account. This may also enable the Social Network and us to link your activities with your personal registration information at their site, and may include notifying your friends about your activities whilst using our Products. We may also use analytics technologies to link your online activities so that we can serve targeted ads. Digital download platform providers, such as Apple’s App and iTunes Stores or Google’s Google Play Store may for example share anonymized IDs with us to help optimize our offerings to you and to help us understand how you are using our Products. Again, if such a platform provider shares this information with us it does so subject to its privacy policy, and the privacy settings of your platform provider’s account. 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.

We do not control (nor act as the controller of) the information that is sent from your device to third parties, including social media platforms, analytics companies and advertising networks which receive information in the normal course of your online activities.

We may collect payment information such as credit or debit card details (including expiration dates) and other billing information such as your name and address in order to verify your purchases, process any refund payments, contact you to resolve any product issues, and/or deliver Products to you. 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

We collect information from your device and activity about the way you use our Products. We may also collect information about you 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 on our Products, such as forums and chat functionality, may be stored, copied or used by SEGA, the public, or third-party companies. By accessing our Products, we may collect technical information from your mobile or computer device, for example your location information where you choose to share this with us, which devices 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, Internet Protocol address, your browser type, browser language preferences and when, how often and how long you interact with our Products, websites and services. We also use software to enable us to provide safe and fair gaming environments for all users of our Products and when you log in to one of our Products, or make purchases. We, and or our third party suppliers may use cookies and similar technologies, or collect data about your device(s) to create a device fingerprint of the components of your specific device(s) and/or build an individual profile of you.

See also our Cookie Policy

We will collect personal information from the messages and reviews you post on our social forums, and when you contact us, for example with a question, problem or comment. If you contact our customer services team by email or post, we will keep copies of your correspondence with us for as long as necessary to deal with your query.

We collect information obtained from your use of our Products from third parties to provide you with an optimal experience, to facilitate use of the Products as advertised, to enable you to play our Products on various platforms and to optimize our Products.

2. How we use the information we collect

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

(a) Registration information

Your registration information enables us to provide you with access to the Products and to supply the Products under the agreements we have with you and the relevant terms of service. 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.

Where 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 post, email, telephone, mobile or in-app messaging about our other products and services. If you no longer want us to use your data in this way or generally change your mind about receiving marketing communications, you can unsubscribe at any time, either by using the unsubscribe option in the communication you receive or by changing your communication settings. 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.

(b) Billing information

This information will enable us to verify your purchases with third party stores and to contact you in order to assist with resolving any problems with your purchases and to process any refund payments that you may be due.

We will also use and analyze information on transactions on your account for our legitimate interests 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 the Products.

(c) Technical and device information

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 anonymous 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 personalized content, helps us understand the features of our Products that appeal to you and allows us to manage advertising, amongst other things.

When you interact or visit our websites, we may automatically collect information about you such as the type of internet browser or mobile device you use, any website from which you have come to any of the SEGA Products and your IP address (the quasi-unique address which identifies your device on the internet) and your operating system, which are automatically recognized by our web server. We use log files to monitor traffic on our Products, resolve technical problems and to detect and prevent fraud. We 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 and for and in our Products. In some cases, including 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 videogames, 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. We also use this information to deliver you personalized content, help us understand the features of our Products that appeal to you and allows us to manage advertising.

(d) Feedback

We use your feedback to reply to your questions or queries, to provide customer support and resolve problems relating to any of our Products under the agreements that we have with you. We will also publish reviews that you submit to us for this purpose about the Products and will conduct analysis of feedback for the purpose of improving and developing the Products.

(e) Third party information

We use information obtained from third parties to provide you with an optimal experience, to facilitate use of the Products as advertised and to enable you to play our Products on various platforms.

We may also work with advertising networks that serve advertisements into our Products, or the websites and products of third parties. Some of those advertisements may be personalized to your interests based on your activity and technical information using cookies, which are stored on your device, or device identifiers.

Certain Products are currently supported by third party advertising partners that serve advertisements (“Third Party Advertisers”), including behavioral, location or interest based advertising (“Interest Based Advertising”) within our Products. These Third Party Advertisers use technology to serve the advertisements and link to them directly into the Products. They may automatically receive your device ID, IP address or geo-location data when this happens. They may also use other technologies (such as cookies, JavaScript, or web beacons) to measure the effectiveness of their advertisements and to personalize the advertising content you see. Please see the list of our Third Party Advertisers in Appendix A used within certain Products, and their respective privacy policies for information regarding their privacy practices. Certain Products are supported by advertisements. Although you may opt out of Interest Based Advertising, you may not be able to opt out of receiving all advertisements. If you do not wish to be served advertisements, please do not use such Products

Opt-Out for Interest Based Advertising

Your mobile device may allow you to opt out of certain Interest Based Advertising.

iOS (iOS v8.0 or later)– On your iOS device (iPhone or iPad), open “Settings > Privacy > Advertising” and turn on “Limit Ad Tracking” to opt-out of interest based ads. Please see additional information from Apple here.

Android (6.0 / Marshmallow and higher)– Open the Settings app on your Android phone, tap Ads and enable “Opt out of interest based ads”. 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 precise location data, or street-level location information, about you (“Precise Location Data”). Your mobile device may allow you to opt out of the collection of Precise Location Data by the Third Party Advertiser in the Product, as further described below.

iOS (iOS v8.0 or later)– In order to disable the collection of Precise Location Data on iOS, you may turn Location Services off for the applicable Product via the menu “Settings > Privacy > Location Services”. Then select the applicable Product and set the “Share My Location” status to “Never”. Please see additional information from Apple here.</p.

Android (6.0 / Marshmallow and higher)– In order to disable the collection of Precise Location Data on Android, you may turn Location off for the applicable Product via the menu “Settings > Apps > [applicable Product] > Permissions > Location”. Then turn off the “Location” button.

3. When we share information

In delivering the Products to you, we may share your personal information with:

• Companies within the SEGA group (which means SEGA companies which are our parent and affiliated companies, our ultimate holding company and its subsidiaries and affiliates) who act for us for the purposes set out in this policy.

• Third parties in order to undertake various activities or services on our behalf in supporting the 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 for the delivery of promotional, digital advertising or other communications.

• Third Party Advertisers in our Products may automatically receive your device ID, MAC address, IP address or geo-location data in connection with the advertising. They may also use other technologies (such as cookies, Java Script, pixels, or web beacons) to measure the effectiveness of their advertisements and to personalize the advertising content you see. Please see the list of our Third Party Advertisers in Appendix A used within certain Products, and their respective privacy policies for information regarding their privacy practices.

• If our business enters into a joint venture, purchases or is sold to or merged with another business entity, your information may be disclosed or transferred to the target company, or new business partners or owners or their advisors.

• We may use the information that you provide if we are under a duty to disclose or share your information in order to comply with (and/or where we believe we are under a duty to comply with) any legal obligation; or to enforce the relevant terms of service and any other agreement; or to protect our rights or the rights of third parties. This includes exchanging information with other companies and organizations such as credit agencies, law enforcement or government bodies or the courts in connection with a criminal investigation, suspected illegal activity, fraud prevention and detection or in legal proceedings.

We do not control information which is sent from your browser to third parties, and may not control certain information which is sent from our Products to third parties, including social media platforms, analytics companies and advertising networks that receive information in the normal course of your online activities.

Personal information may be transferred to other countries where SEGA or our service providers maintain operations. These countries may not have equivalent data protection laws to the country from where you access the 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 data to that in the EU, through its domestic law or its international commitments.

Where SEGA transfers personal information we will seek to take account of any applicable legal obligations relevant to personal information transfers. In the case of transfers of personal information subject to the law of the European Union to a country which is not part of the European Economic Area, we will, in the absence of an EC adequacy decision relevant to the destination country, seek to rely on appropriate safeguards such as a valid Privacy Shield certification (in the case of a data transfer to a Privacy Shield certified US recipient – https://www.privacyshield.gov/welcome) or enter into appropriate EC approved standard contractual clauses relevant to personal data transfers between data controllers or between a data controller and a data processor, (see http://ec.europa.eu/justice/data-protection/international-transfers/transfer/index_en.htm).

4. Security and data retention

We place great importance on the steps we take, including physical, technical and organizational measures, to protect your information from unauthorized access and against unlawful processing, accidental loss, destruction and damage. Where you have chosen a password which allows you to access any of the 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 username, personal information and/or password. Your personal information will be retained by us for the duration of your use or access to our Products and may be retained for a period after this time as necessary and relevant to our legitimate operations, 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 enforce any obligations in our agreements, the relevant terms of service, any game “sun-setting” requirements or to identify, issue or resolve legal proceedings. 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. 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.

5. Your choices and rights

You have options and choices over how we use your information. We provide you with tools to access and update specific information relating to your use of the Products at any time. If you need to sign in to access certain Products, you can update and amend your key contact information directly. We respect the rights you may have under applicable law to request access to your personal information and where applicable, to request to receive that information in a commonly used electronic format (or ask for this information to be provided in that format to a third party where feasible). You may also have the right under applicable law to request the correction or erasure of your personal information, to seek to object to the further processing under certain circumstances of your information or to request that the processing of specific information about you is restricted while we verify or investigate your concerns about this information. We do not verify the correctness of your personal information. If you remain unhappy with a response you receive, you can also refer the matter to your data protection supervisory authority if your personal information is subject to the law of the European Union (see http://ec.europa.eu/justice/data-protection/bodies/authorities/index_en.htm)

6. Children’s information

If SEGA learns that personal information of users under the age of 13 or other applicable age of consent has been collected, other than for support of the internal operations and/or for our legitimate interests, SEGA will take reasonable steps to remove such information. We may collect non-personally identifiable information from children, such as country settings and language settings to ensure compliance with the applicable law for the specified country. If you believe that we may have unintentionally collected personal information about your child, you may contact us using the details provided below.

7. Your questions and how to contact us

If you have any questions or comments about this policy or our practices you can contact us:

SEGA Games Co., Ltd.
Attn.: Contact for Personal Information
Osaki Garden Tower
1-1-1 Nishi-Shinagawa
Shinagawa-ku, Tokyo 141-0033
Japan
Email: sgcsupport@sega.com

APPENDIX A

Third Party Advertising for certain Products

Last updated – July 13, 2018

For the most up-to-date list of Third Party Advertisers, please contact us.

Shin Megami Tensei Liberation Dx2

SEGA Pocket Club Manager