SEGA CORPORATION PRIVACY POLICY

Last updated: December 07, 2021.

SEGA CORPORATION (with certain affiliates under our control “We”, “Our” or “Us”) understands that you care about how your information is collected, used and shared. Our Privacy Policy will describe how We collect and process your personal information through our websites, products and services (collectively, “Sega Services”).

By using Sega Services, you acknowledge that you have read and also understand the terms of this Privacy Policy, including how We use your personal information.

This Privacy Policy may be revised from time to time and any such revisions will be reflected by the “Last updated” date above.

Personal Information Controller

SEGA CORPORATION, located at Sumitomo Fudosan Osaki Garden Tower 1-1-1 Nishi-Shinagawa, Shinagawa-ku, Tokyo 140-0033, is the data controller of personal information collected and processed through Sega Services.

Collecting Personal Information

We collect your personal information in order to continually improve Our products and services and to provide you with the best version of Sega Services.

We collect:

• Information that you provide to Us. Any information you provide to Us in relation to Sega Services will be stored carefully by Us. You may choose not to provide Us with your personal information, but that might mean you will not be able to use certain aspects of Sega Services to the fullest. Such information includes registration information, billing information and feedback from you.
• Information automatically collected by Us. When you use Sega Services, certain types of information will be automatically collected and stored by Us. We use cookies and other unique identifiers to help Us provide you with the best experience. Other collected information may be technical and device information from your device or computer that you use to access Sega Services.
• Third-Party Information. From time to time, information about your use of Sega Services may be shared with third-party platforms and services.

Examples of Information Collected

You provide your personal information to Us when you use, access or interact with Sega Services.

Some examples of personal information that might be supplied by you: Your name, address and phone number, billing information, age, location, email address, personal description and any other possible identifying information.

Information We may automatically collect and analyze:

• Internet protocol (IP) address used to connect your computer to the Internet;
• Login, email address, password;
• Location of your device or computer;
• Interaction information, such as usage, network details, including information about your internet service provider;
• Device metrics such as when a device is in use, application usage, connectivity data and any errors or bugs;
• Sega Services metrics, such as occurrences of technical errors, your interactions with service features and content, your setting preferences.

How Personal Information is Used

We will use the collected personal information to ensure We can provide you with the best experience when you use and access Sega Services. By analyzing the way you use and access Sega Services, including any feedback or troubleshooting information, this all helps Us understand how we can improve our services.

• Purchases and Billing. Your personal information will be used to fulfil orders, deliver products and services as well as process payments, including communicating and confirming purchases, payments and refunds.
• Registration and Personal Identification. Your personal information will be used to identify you when you sign-in to access certain services, when you create a personal profile and also helps Us identify you for billing and purchases purposes.
• Troubleshooting and Improving Sega Services. Information collected will be used to help Us identify and fix errors, improve performance and the overall effectiveness of Sega Services all with the aim to provide you with the best experience possible.
• Your personal information will be used by Us to recommend products and services to you and to personalize your experience whenever you log in, access or use Sega Services.
• We may also have to comply with certain legal and/or regulatory obligations that require Us to collect, process and store your personal information for certain functions, such as when processing payments.
• Your personal information will be used by Us to communicate with you regarding Sega Services, including updates, changes, feedback and even special events.
• Advertising and Third-party Information. We may use your personal information to show tailored offers to you, to facilitate sharing on social networks and to facilitate your gameplay.
• Fraud and Credit Risks. Your personal information will be used to prevent, detect and identify fraud and abuse. Collected information will be used to ensure your security and the security of others.
• We may ask for your consent to process your personal information for specific purposes. Whenever you give Us your consent, you may withdraw your consent at any time and We will stop processing your personal information.

Sharing Your Personal Information

We respect your privacy. We will protect your privacy. We are not in the business of selling your personal information to others. Most importantly, we want you to know that you have the ability to choose what information you would like to share with Us and what information you would like for Us to share with third parties.

• Affiliates within the wider SEGA group. In order to provide you with the best services, We may share collected information with Our affiliates and/or subsidiaries and/or ultimate parent company to ensure you receive a seamless user experience between Our different products and services.
• New owners or reorganization. In the event of a business restructure, sale, purchase or joint venture We may have to provide information regarding Our business and operations to the new owners and this may include your personal information.
• Third-Party Service Providers. We are able to provide Sega Services to you through the help and collaboration of other companies or professionals to perform necessary functions on Our behalf (collectively, Third-Party Service Providers). Third-Party Service Providers must adhere to this Privacy Policy and also maintain a privacy policy of their own.
• Legal obligation. We may share your personal information where We are under a duty to, are authorized to or required to do so, by law.
• Notwithstanding the above, Legal obligation, you will receive notice when your personal information might be shared with third parties and you will have the opportunity to choose not to share your personal information.
• Outside of the European Union. When sharing your personal information to countries outside of the European Union, We will ensure that your personal information is shared and transferred in accordance with this Privacy Policy as well as any relevant data protection and privacy laws.

Security

We prioritize protecting your privacy and have internal procedures and safeguards in place to maintain security during the collection, storage and disposal of your personal information. These security measures are aimed to protect you and to ensure that your personal information remains private and protected. Because of these security measures, it may mean that on occasion We may request from you proof of identity before We can disclose personal information to you.

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 Sega Services at any time. If you need to sign in to access certain Sega Services, you can update and amend your key contact information.

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 deletion 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.

If you remain unhappy with a response you receive, and are in the European Union, you may also refer the matter to your data protection supervisory authority.

(see http://ec.europa.eu/justice/data-protection/bodies/authorities/index_en.htm).

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 are used to remember and recognize your preferences, so that We can provide a better personalized experience for you.
• Cookies also help 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 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.

Third-Party Advertisers

Sega Services may, from time to time, collaborate with third-party advertisers. These third-party advertising partners may collect information about you when you interact with their content, advertising and other services they may provide.

• 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, open “Settings > Privacy > Apple Advertising” and turn on “Personalized Ads” to opt-out of interest based ads.

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 Sega Services you are using.

• Opt-out for Location Data

Certain third-party advertisers in Sega Services may collect precise location data, or street-level location information, about you (Precise Location Data). Your device may allow you to opt out of the collection of Precise Location Data by the third-party advertiser in the Sega Services, 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 Sega Services via the menu “Setting > Privacy > Location Services.” Then select the applicable Sega Services and set the “Share My Location” status to “Never.”

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 Sega Services via the menu “Settings > Apps > [applicable Sega Services] > Permissions > Location.” Then turn off the “Location” button.

Children’s Information

It is important to Us to protect the privacy of young children. Therefore, We do not knowingly or intentionally collect or maintain personal information or non-personally identifiable information from users under 13 years of age in the United States and the applicable age of consent in the European Union, other than as permitted by law in support of Our internal operations (inside Japan) and for legitimate interests (outside Japan).

If We learn that we have collected personal information of users under the age of 13 (or other applicable age of consent) other than personal identifiers for supporting the internal operations of Sega Services (inside Japan) and/or for legitimate interest (outside Japan), 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 at dataprivacy@sega.com.

For California Residents

The California Consumer Privacy Act (CCPA) is a data privacy law that applies to certain businesses when collecting personal information from California residents. The CCPA went into effect on January 1, 2020.

California consumers have the following rights under CCPA:

• The right to know, access and delete their personal information under the CCPA;
• 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 your personal information; and
• The right not to be discriminated against for exercising your privacy rights.

We do not discriminate or penalize you for exercising your privacy rights. To exercise any of your rights under the CCPA, please contact Us at dataprivacy@sega.com or via fax at +81-50-3153-7908 (a toll free number is currently being established and will be updated as soon as possible). Please be ready to provide Us with your name, address and email address and please be aware that 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.

For Nevada Residents

For consumers residing in Nevada, Senate Bill 220 went into effect on October 1, 2019. If you are a Nevada resident, you have the right to opt-out of the sale of the following personal information:

• First and last name;
• Physical address, including the name of the city or town;
• Email address;
• Telephone number;
• Social security number;
• Identifier that allows a specific person to be contacted; or
• Any other information collected through Sega Services.

To exercise any of your rights, please contact Us at dataprivacy@sega.com. Please be ready to provide Us with your name, address and email address and please be aware that 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.

We do not sell your personal information.

For further information or if you have any questions or comments, please contact us at dataprivacy@sega.com.