This privacy notice is issued by Konami Digital Entertainment Co., Ltd. (hereinafter referred to as the "Company”, “we”, “our”, or “us”), a company based at 1-11-1 Ginza, Chuo‐ku, Tokyo 104-0061 Japan.
This privacy notice describes how the Company will use your personal data when you play our game “PES CLUB MANAGER” (“Game”) that you are about to play.
This privacy notice also describes your rights to the protection of personal data, including the right to object to any processing of personal data that we carry out. More information about your rights and how to exercise them is set forth in the “Your rights and requests to the Company” section.
We may change, add to, or delete any part of this privacy notice from time to time. You can obtain the latest version of this privacy notice from [https://legal.konami.com/games/asj/en/].
1. Our use of your personal data
We process your personal data in accordance with the applicable EU and Member State regulations on data protection, and in particular, the General Data Protection Regulation (EU) 2016/679 ("GDPR").
Your personal data may be used in order to help us provide you with our Game and any Game related services (together with the Game, “Game Service”).
(a) Categories of personal data we collect
Below are the categories of personal data that we collect when you use our Game. Unless otherwise stated below, personal data in parenthesis are examples of the data we collect.
| Purpose | Categories of Personal Data | Lawful Basis |
|---|---|---|
| To provide the Game Service |
Identifiers (User ID, instance ID for Firebase) Network information (IP address) Transaction information (purchase history) Usage data (play data, log, and user data such as user content you post, language and country or region) |
Legitimate interest |
| To serve in-Game ads |
Identifiers (ad ID) Device information (OS) Network information (mobile country code, mobile network Code, browser info) Usage Data (Play data, such as Game’s name and ID) |
Consent |
| To improve the quality of, or newly develop, our products and services | Mobile measurement related information such as network information (IP address), Identifiers (ad ID), device information (OS, CPU type), and transaction information (amount paid) | Legitimate interest |
| To market and promote our products and services | Legitimate interest | |
| To establish our business strategy | Legitimate interest | |
| To detect any suspected violation of our Rule* and determine our appropriate actions against any such suspected violation |
Identifiers (User ID) Network information (IP address) Usage data (play data) |
Legitimate interest |
*“Rule” means any terms, conditions, regulations and/or any other rules that Company has set with regard to your use of our products and services, including but not limited to, the Game Service. Rule may be presented to you by us in various names, including but not limited to, “Terms and Conditions”, “Terms of Use”, “End-User License Agreement”, and “Operation Rules”.
(b) Your data that may be disclosed to other users
Please be advised that some of your data collected by us may be disclosed to other users. The purpose of such disclosure is to provide better Game experiences to our users, including you. Your data that will be disclosed is as below.
- Data disclosed in the Game: player name, level and icon, and ranking data
- Data disclosed on our Game-related websites: player name and ranking data
In addition to the above, if you post any contents on in-Game forums, posted content, together with your player name, and date and time of the post, will be disclosed to other users who have access to that forum.
(c) Data retention period
We keep your personal data as long as necessary to ensure that we can continue to offer you the Game until (i) you ask us to delete your personal data that is processed for our Game Service, or (ii) the provision of our Game Service to the market is terminated.
The data retention period for your personal data by us after the events of (i) or (ii) occur is as follows:
- Period necessary to respond to legal obligations
- Period necessary for dispute resolution
- Period necessary for performance of the contract
- In the absence of the above, up to 6 months from the termination of the provision of the Game Service
(d) Your consent to in-Game ads
You will be offered to see ads while you play our Game.
By choosing to see such ads, you are consenting to our processing of your personal data for the purpose of serving in-Game ads.
You can opt-out from this processing by resetting your ad ID.
Apple: https://support.apple.com/HT205223
Google: https://support.google.com/ads/answer/2662922/
2. Our sharing of your personal data with other companies
We share personal data with other companies, including in order to ensure the quality of our games and services so that we are able to provide you with the game experience you expect from us and can enjoy, as well as to protect our business interests.
(a) Sharing with our group companies
We share personal data with other companies in our group, including affiliates in Japan, Europe, the United States of America, and Hong Kong, e.g., Konami Business Expert Co., Ltd. (Japan), Internet Revolution, Inc. (Japan), and specifically, those listed at https://www.konami.com/corporate/en/subsidiaries/. In these cases, our group companies that receive your personal data will use the personal data in accordance with this privacy notice and their respective privacy policies.
(b) Sharing with third parties
We also share personal data with third parties, including service providers (e.g., companies providing servers storing data).
Below are the categories of third parties with which we share personal data.
| Category | Location |
|---|---|
| Processor – Service providers (cloud service) |
US, Japan Locations of the data centers used by Google LLC and/or its affiliate(s) for Firebase services are explained at: https://www.google.com/about/datacenters/locations/ |
| Processor – Service providers (analytics and measurement service) | Germany and Netherlands |
| Processor – Service providers (reseller) | Japan |
(c) Sharing with other entities
We may also share your personal data with other entities not specified above (i) in the event of organization restructuring or (ii) if it is requested by judicial, administrative, or other public authorities (including authorities outside your district of residence).
In every case, we have appropriate safeguards in place to ensure the security and confidentiality of your personal data.
(d) Tracking by Adjust technology
We use mobile analytics and attribution services provided by Adjust K.K. (“Adjust Technology”) to track our marketing performance, to match our campaigns with you, to understand how you engage with our Game, and to track your interactions in our Game in real time.
For more information about Adjust Technology, please visit Adjust K.K.’s privacy policy at: https://www.adjust.com/terms/privacy-policy/
If you want to opt-out from tracking by Adjust technology, please visit Adjust K.K.’s opt-out page at: https://www.adjust.com/forget-device/
3. Transfer of your personal data to other countries
The Company may send your personal data to other companies outside your country. In particular, if you live in the European Economic Area (EEA), your personal data may be transferred to companies located outside the EEA. When this is the case, either (i) the countries in which those companies are located must be approved by the European Commission as countries ensuring an adequate level of protection of personal data, or (ii) the Company must adopt and execute Standard Contractual Clauses to oblige the company that receives your personal data to use it fairly and legally.
The Company will provide details of the safeguards to you upon request.
4. Your rights and requests to the Company
You have the following rights that you can exercise with the Company.
- Information regarding your personal data processing: You have the right to obtain from us all the requisite information regarding our personal data processing activities that concern you (Articles 13 and 14 GDPR).
- Access to personal data: You have the right to obtain from us confirmation as to whether or not personal data that concerns you are being processed, and where that is the case, access to the personal data and certain related information (Article 15 GDPR).
- Correction or erasure of personal data: You have the right to require the Company to correct inaccurate personal data that concerns you without undue delay and to complete any incomplete personal data (Article 16 GDPR). You may also have the right to require the Company to erase the personal data that concerns you without undue delay, when certain legal conditions apply (Article 17 GDPR).
- Restriction on processing of personal data: You may have the right to require the Company to restrict the processing of personal data, when certain legal conditions apply (Article 18 GDPR).
- Portability of personal data: When certain conditions apply, you are entitled to receive your personal data in a systematic format available for general use, so that the data may be shared with another company (Article 20 GDPR).
- Objection to processing of personal data: You may have the right to object, on grounds relating to your particular situation, at any time to the processing of personal data concerning you, when certain legal conditions apply (Article 21 GDPR).
- Not to be subject to automated decision-making: You may have the right not to be subject to automated decision-making (including profiling) based on the processing of your personal data, insofar as this produces legal or similar effects on you when certain conditions apply (Article 22 GDPR).
You can use these rights by contacting us at the following link:
privacynotice@faq.konami.com
You can contact our Data Protection Officer at the following link:
dpo-team@konami.com
You can contact our representative in the European Union (EU) at the following link:
Konami Digital Entertainment B.V.
rep-gdpr@konami.info
If you believe we have misused your data or violated any data protection regulations, you may file a complaint with a Data Protection Authority, for example, the Authority of your place of residence within the EEA.
If you have any inquiries concerning our products or services, please contact us at the following address:
https://www.konami.com/games/inquiry/