SEGA CORPORATION MOBILE PRIVACY POLICY

LAST UPDATED ON August [  ], 2020

Introduction

SEGA CORPORATION (with certain affiliates under its control, “we” or “us”) collects information about you when you use our mobile, online and downloadable products and services (“Products“).

This privacy policy explains how we collect, use, share and protect your information when you use our Products, as well as your rights and choices about such use and sharing.

By using our Products you acknowledge that you have read and understand the terms of this privacy policy, including how we use personal information.

SEGA CORPORATION located at Sumitomo Fudosan Osaki Garden Tower 1-1-1 Nishi-Shinagawa, Shingawa-ku, Tokyo 140-0033 and is the data controller for the information collected via our Products.

The privacy policy may be revised periodically, and any such revisions will be reflected by the “Effective Date” above. Please revisit this page to stay aware of any changes. If we make material changes to this privacy policy, we will provide you with additional notice of such changes by providing in-Product alerts or via email to you.

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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:

1. Registration information: information you give us when you sign up to access our Products, or other information you choose to give us.
2.  Billing information: information provided by you and/or third party stores.
3. Technical and device information: information from your mobile or computer device when you use our Products.
4. Feedback: your questions, suggestions or views on the Products.
5. Third party information: information about your use of our Products that is shared with third party platforms and services connected with our Products.

Learn more

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 provide Products you request;

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

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

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

(vi) to allow participation in special events or contests (if specifically approved by you);

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

(viii) 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 billing-related problems;

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

(iv) to protect you and the Products by seeking to detect and prevent fraud or other acts in breach of our terms of service or policies relevant to the 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;

(vi) to provide safe and fair gaming environments;

(vii) to track consents for use of personal information related to our Products;

(viii) to serve advertisements within the Products;

(ix) to customize and optimize the targeting of advertising both on our Products and across third party websites, apps and products;

(x) to operate and improve our Products; and

(xi) to fix errors.

(d) Feedback:

(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 the 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.

Learn more

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) Affiliates within the wider SEGA group.

(b) Third party service providers who carry out various activities and services in support of or for the benefit of our Products.

(c) Advertising Partners for the service of advertisements within our Products.

(d) Marketing Partners for marketing or promotions such as Mailchimp, based on your communication preferences.

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

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

Personal information may be transferred to other countries where we or our service providers maintain operations. These countries may not have equivalent data protection laws to the country from where you access the Products.

Learn more

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 CORPORATION 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.Learn more

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 the personal information that you provide to us.

You have control over if we, and/or our partners, use personal information to provide targeted advertisements and you may withdraw consent related to the use of personal information to serve you targeted advertisements.

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.

Learn more

California residents have additional rights under California law.

Learn more

Nevada residents have additional rights under Nevada law.

Learn more

6. Children’s information

Protecting the privacy of young children is especially important to SEGA CORPORATION. For that reason, we do not knowingly collect or maintain personal information or non-personally identifiable information from users under 13 years of age in the United States, and under the applicable age of consent in the European Union, other than as permitted by law in support of our internal operations (in the U.S.) and legitimate interests (outside the U.S.).

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.

SEGA CORPORATION

Attn.: Contact for Personal Information

Osaki Garden Tower

1-1-1 Nishi-Shinagawa

Shinagawa-ku, Tokyo 141-0033

Japan

Email:

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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:

(a) Registration information

When you register or sign up to use our Products, for contests or special events, we will collect information about you, which, depending on the Product, contest or event, may include your name, contact details, a password and security answers and may collect additional information that you choose to provide such as age, gender or personal preferences. We will also collect your contact information when you sign-up to receive our marketing communications.

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 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. This may also involve the use by us of analytics technologies to link your online activities so that we can serve targeted ads.  First party platforms, such as Apple’s App Store or Google’s Google Play store may for example share anonymized ids with us to help optimise our offerings to you and to help us understand how you are using our Products. If the first party platform shares this information with us it does so subject to its privacy policy, and the privacy settings of your first party platform 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.

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 that receive information in the normal course of your online activities.

(b) Billing information

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 look at and engage with. Information obtained from social features related to Products, such as public forums or chat, may be stored, copied or used by SEGA CORPORATION, the public, or third party companies.

By accessing our Products, we will 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 will automatically collect information such as your operating system, Internet Protocol address, country and language settings, MAC address, your browser type, installed Products, hardware type, browser language preferences and when, how often and how long you interact our Products, as well as other application usage data. We also use software to enable us to provide safe and fair gaming environments for all users of our Products. 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 a build an individual profile of you.

Use of 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 site, 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.
• Cookies that are used to remember and recognize your preferences, so that We can provide a better personalized experience for you.
• Cookies also helps with preventing fraudulent activity, improving security and delivering 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 download and install Google’s Opt-out Brower 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.

(d) Feedback:

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 a limited period of time after completing your query.

(e) From third parties:

We collect information obtained from your use of our Products from third party analytics providers and other third parties to provide you and other customers 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 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 first 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 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.

When you interact or visit our websites, we will 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 CORPORATION sites, your IP address (the quasi-unique address which identifies your device on the internet), country where the device is located, language settings 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 or other’s 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, track consents to use of personal data, 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 relevant terms of service. 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) From and to third parties:

We use information obtained 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 provide attribution credit for advertisements for our Products.

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 and using cookies or device identifiers.

Certain of our Products are supported by third party ad mediators or ad networks that serve advertisements (“Third Party Advertisers”), including behavioral or interest based advertising (“Interest Based Advertising”) within our Products. These Third Party Advertisers use technology to send, directly to your device, the advertisements and links that appear in the Products. Unless you opt-out as described below, the Third Party Advertiser will automatically receive from Products your device ID, MAC address, IP address or geo-location data when this happens; SEGA CORPORATION does not collect nor store such data from these sources. Additionally, the Third Party Advertiser may collect such information directly via our Products. The Third Party Advertisers may also use other technologies (such as attribution technologies, cookies, JavaScript, 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.

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 – 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: https://support.apple.com/en-us/HT202074

Android – 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 8 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: https://support.apple.com/en-us/HT203033.

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 our subsidiaries and affiliates, our ultimate holding company and its subsidiaries and affiliates) who act for us for the purposes set out in this policy.
• Third parties with whom we share your information in order to undertake various activities or services on our behalf in supporting the Products, including authorizing our third party partner’s subprocessors to process relevant data only as needed to provide the respective service. This includes payment processing providers facilitating credit and payment card transactions, website and application support and hosting providers for online 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, JavaScript, 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.

By using the Products, you consent to the sharing, transfer and/or sale of your personal information as provided in this Privacy Policy and the Terms of Use.   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 we 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.

4. Security and data retention

We take reasonable, physical, 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 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 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, when you withdraw consent (as applicable) or at your request.

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.

Your browser settings may allow you to automatically transmit a “Do Not Track” signal to online services you visit. Note, however, there is no industry consensus as to what site and app operators should do with regard to these signals. Accordingly, we do not monitor or take action with respect to “Do Not Track” signals or other mechanisms.  For more information on “Do Not Track,” visit http://www.allaboutdnt.com .

Please contact us as described in Section 7 “Contact Us” to exercise any of these rights.

If you remain unhappy with a response you receive, and are in the European Union, 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).

For California Residents

Your California Privacy 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 as described below in Section 7 “Contact Us”. Requests must include “California Privacy Rights Request” in the first line of the description and include your name, street address, city, state, and ZIP code.

Your Rights under the California Consumer Privacy Act (the “CCPA”)

Our customers who are California residents have the following rights under the CCPA:

• The right to request the deletion of their personal information;

• With respect to the collection of personal information, the right to request, not more than twice in any twelve (12) month period, the following: (i) categories of personal information we have collected about that consumer; (ii) categories of sources from which the personal information is collected; (iii) business or commercial purpose for collecting or selling personal information; (iv) categories of third parties with whom we share personal information; and (v) specific pieces of personal information we have collected about you;

• With respect to the sale and/or disclosure of personal information, the right to request, not more than twice in any twelve (12) month period, the following: (i) categories of personal information that we have collected about the consumer; (ii) categories of personal information that we have sold about the consumer and the categories of third parties to whom the personal information was sold, by category or categories of personal information for each third party to whom the personal information was sold; and (iii) categories of personal information that we have disclosed about the consumer for a business purpose;

• The right to opt-out of the sale of personal information; and

• The right to not be discriminated against for exercising any of the above described rights.

To exercise any of your rights under the CCPA, please contact us at 1-800-XXX-XXXX, at our website at www.XXXXXXX.com, or via email at mobilesupport@sega.com and be ready to provide your name, address, and email.  To exercise your right to opt-out of the sale of personal information, you may click on the following link:  Do Not Sell My Personal Information.  We may ask for other information in order to confirm your identity.  Any information we receive from you in order to confirm your identity will solely be used for such verification purposes.

Further Disclosures Under the CCPA

During the past twelve (12) months, we have collected the following categories of personal information from the following sources, for the following purposes, and have shared them with the following third parties:

We do not believe that we have sold consumers’ personal data in the preceding twelve (12) months.

For Nevada Residents

Our customers who are Nevada residents have the right at any time  to request that we do not sell the following information regarding them to third parties: (1) the customer’s first and last name; (2) the customer’s physical address which includes the name of a street and the name of a city or town; (3) the customer’s e-mail address; (4) the customer’s  telephone number; (5) the customer’s social security number; (6) the customer’s identifier that allows a specific person to be contacted; or (7) any other information concerning a customer collected from the customer through our Internet website or online service and maintained in combination with an identifier in a form that makes the information personally identifiable.

To exercise your right to opt out of the sale of Covered Information under Nevada law, please contact us at mobilesupport@sega.com and be ready to provide your name, address, and email. We may ask for other information in order to confirm your identity.  Any information we receive from you in order to confirm your identity will solely be used for such verification purposes.

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 SEGA CORPORATION Data Protection Officer (mobilesupport@sega.com).

6. Children’s information

If we learn that we have collected personal information of users under the age of 13 or other applicable age of consent, other than persistent identifiers for support of the internal operations of the Products (in the U.S.) and/or for our legitimate interests (outside the U.S.), then we 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:

By email at: mobilesupport@sega.com

By writing to us at:

SEGA CORPORATION

Attn: [INSERT DEPARTMENT]

Sumitomo Fudosan Osaki Garden Tower

• Nishi-Shinagawa, Shinagawa-ku

Tokyo 140-0033, Japan

You can also contact our Data Protection Officer at mobilesupport@sega.com

Appendix 1 – Third Party Information Sharing for certain Products