For our child-friendly privacy page, visit our website https://legal.konami.com/kde/kidsprivacy/en/.
KONAMI SERVICES PRIVACY NOTICE
This Konami Services Privacy Notice (this Notice) is provided to you by Konami Digital Entertainment Co., Ltd. (Konami) and explains to you, as a user of our products and services (Konami Service), how we collect, use, and protect your personal data.
We may change, add to, or delete any part of this Notice from time to time. You can obtain the latest version of this Notice from our website [https://legal.konami.com/games/att/en/].
PART I. SERVICE-SPECIFIC INFORMATION
(GAMES)
A. GENERAL PROCESSING
1. Categories of personal data we process
Below are the categories of your personal data we may process when you play Konami’s games (Game). For the avoidance of doubt, the Game forms part of Konami Service.
· Identifiers, such as user identifiers designated by us (user ID) and those designated by third parties, such as, platform IDs and instance ID for Firebase.
· Device Information, such as OS version.
· Network information, such as IP address.
· Usage data, such as the following.
- User data: any choice that you made or information about you that you send us through your use of the Game, such as selected language and country or region.
- Play data: the fact that you have installed and played a particular Game, and any record of your in-Game activities, i.e., saved Game data, including your in-Game items and virtual currencies.
- Log
- Fraud prevention information: any data necessary for us to prevent unauthorized or fraudulent use of the Game.
· Transaction information, such as records of your in-Game purchases.
2. Purposes and legal basis of our processing of your personal data
Below are the purposes for which we may process your personal data.
· To provide you the Game and its related services.
· To improve the quality of Konami Service, including, the Game.
· For our development of new Konami Service, including, the Game.
· To promote and market Konami Service, including, the Game.
· To establish our business strategy.
· To detect any suspected violation of our Rule (defined below) and determine our appropriate actions against any such suspected violation.
· To comply with legal obligations or respond to legitimate requests from public authorities.
· For dispute resolution, including the establishment, exercise or defence of legal claims.
· For performance of the contract between us and our business partners (including licensors)
The legal basis of our processing of your personal data for the purposes above is ‘legitimate interest’.
“Rule” means any terms, conditions, regulations and/or any other rules that Konami has set with regard to your use of Konami Service, including but not limited to, the Game. Rules may be presented to you in various names, including but not limited to, “Terms and Conditions”, “Terms of Use”, “End-User License Agreement”, “Operation Rules”, and “Community Guideline”.
Explanations of each lawful bases can be found in Section C - 3. Lawful bases.
B. ADDITIONAL PROCESSING
In addition to our general processing explained in Section A., we process your personal data explained below depending on each function and the Game you play have.
Again, explanations of each lawful bases can be found in Section C - 3.Lawful bases.
1. Mobile measurements
Our mobile Game may use or implement either or both of the followings.
In such case, the legal basis of our processing of your personal data is ‘legitimate interest’.
Any data collected for the purposes explained in this section are further referred to in this Notice collectively as Mobile Measurement Data.
a. Adjust technology
We may use mobile analytics and attribution services provided by Adjust K.K. (Adjust Technology) in our mobile Game 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.
Your personal data will be collected through your use of our mobile Game and will be shared with Adjust K.K. for this purpose.
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/
b. Software Development Kit
We may implement our software development kit (SDK) in our mobile Game and collect following categories of personal data and use them for the promotion and marketing of Konami Services.
· Identifiers, such as user ID, ad ID, and cookie identifier.
· Device information, such as OS, device name, and language settings of the device.
· Network information, such as IP address, country, and PHP session ID.
· Usage data, such as the following.
- Play data: app ID, app version, time of log-in or registration
2. In-Game advertisements.
If the Game you play displays in-Game advertisements (Ads), we process the categories of personal data explained below in addition to those explained in Section A, for the purpose of serving you personalized in-Game Ads that are likely to suit your interests.
· Identifiers, such as, ad ID
· Device information, such as, OS
· Network information, such as mobile country code, mobile network code, and browser information
· Play Data, such as app ID, and app name
We rely on your ‘consent’ to process your personal data for this purpose.
3. In-Game communication tools.
If the Game you play has functions that allow you to communicate with other users (such as, forums, text messaging, and text or voice chat) (Communication Tools), we process any personal data you enter or say using such Communication Tools, to provide you and other users with the better Game experience.
Please be aware that these Communication Tools are designed to share what you have entered or said to other users, and therefore, whatever you enter or say will be disclosed to other users. We strongly encourage you not to disclose any information that can or may be used to identify or contact you in any way. Typical examples are your name, address, e-mail address and phone number, but do not forget that there is other information you should be careful when disclosing, such as, the school you go, where you work, your social networking services account, age, and so on.
Remember that if the other users can see or hear what you entered or said, it is the same as it being disclosed to the public. You may have options to whom your content will be shared. Be careful with whom and what you are sharing.
The legal basis of our processing of your personal data for the purposes above is ‘legitimate interest’.
4. Incentives.
We sometimes offer in-Game incentives for one Game to the users who have played or are playing our another Game (Other Game).
For us to be able to check who has or has not played the Other Game, we will seek if there is any play data of the Other Game (either on your device or on our game server) after you start playing the Game. For example, we may seek play data for the Other Game released in 2020 to check who has or has not played that Other Game in order to decide whether or not to offer in-Game incentives for its sequel released in 2021.
The legal basis of our processing of your personal data for the purposes above is ‘legitimate interest’.
5. Game-related surveys.
We sometimes ask you to answer our surveys in relation to the Game. Your answers to our survey will be used to improve the Game you play or other Konami Service, or for the development of new Konami Service.
The legal basis of our processing of your personal data for the purposes above is ‘legitimate interest’.
6. Event.
Some in-Game event may serve as a qualifying event (Qualifying Event) for the events held independently from the Game (such as, e-Sports events) (Event). If you join such Qualifying Event and qualify for the Event, your personal data related to your use of the Game during such Qualifying Event will be used to run the Event.
The legal basis of our processing of your personal data for the purposes above is ‘legitimate interest’.
7. Statistical data.
We may process your personal data explained in Section A to create aggregate statistical data about the Game to share such statistical data with our business partners, including but not limited to, licensors.
Although we may process your personal data for this purpose, aggregate statistical data shared with our business partners does not and will not include any information that may identify you.
The legal basis of our processing of your personal data for the purposes above is ‘legitimate interest’.
C. RETENTION PERIOD, DATA SHARING, AND LAWFUL BASES
1. How long your personal data are retained by us
For any processing explained in Sections A and B above, we keep your personal data related to the Game that we offer you as long as necessary to ensure that we can continue to offer you that Game. We keep your personal data for up to six (6) months after we stop using your personal data for such purpose, unless we have to retain it for a longer period of time for dispute resolution, to comply with legal obligations, and/or for performance of the contract between us and our business partners (including licensors).
2. Who we share your personal data with
List of our processors can be found here [https://legal.konami.com/kde/processor-list/].
Please also see PART II - Section 4.
3. Lawful bases
Legitimate Interest: this means our interest in operating our business to deliver high-quality Konami Services in the most enjoyable and secure way for you. Where we rely on legitimate interests to process your personal data, we first consider how this may benefit, or pose risks, to you. We will only collect and use your personal data for our legitimate interests where we have made sure that there are no unacceptable negative risks to you, and you always have a right to object to our use of your personal data (see PART II - Section 7). To find out more, please contact us as explained in PART II - Section 8.
Contract: this means we use your personal data where we need to so that we can do what we have promised for you (such as providing in-Game purchases), or you have promised for us (such as paying us for in-Game purchases), under any contract we have with you (or to take steps at your request before entering into such a contract).
Consent: this means we use your personal data where we have obtained your clear, specific and freely given consent (or the consent of your parent/guardian if you are below the age at which the consent of your parent/guardian is no longer required by applicable law). To rely on your consent, we have to provide you with enough information in advance to make up your mind on whether you are happy for us to use your personal data for the purpose we have explained. We also have made sure that you have actively provided your consent to us (we cannot assume or infer your consent) and that we have a record of it. You never have to consent to our use of your personal data and can always change your mind and withdraw your consent easily at a later date (see PART II - Section 7), using the method explained to you when we obtained your consent in the first place.
legal obligation: this means we use your personal data where we are required to comply with a legal obligation.
PART II. GENERAL INFORMATION
We explain further below with more general information about how we process your personal data, including how we protect your personal data and how you can exercise your right with regard to your personal data.
I want to know more about Konami as the controller of my personal data
Konami Digital Entertainment Co., Ltd. is a Japanese company which specialises in developing ‘online’ and ‘offline’ games, such as computer, console and mobile app games, trading card games, and related music and video content. We also organise events and competitions related to these games. We are based in Tokyo, Japan and our company’s main office address is 1-11-1 Ginza, Chuo-Ku, Tokyo 104-0061, Japan. You can find out how to contact us in Section 8. More information about us is on our website: https://www.konami.com/games/corporate/en/
I want to know more about what “your personal data” means
When we refer to “personal data” we mean any information which relates to you as an identifiable individual. A wide range of information can be your “personal data”. Some examples you would expect are your name, email address, home address and telephone number. Some less obvious examples include your gameplay history and the fact that you have won prizes in our competitions. We explain in PART I the personal data which we may collect about you, depending on the type of Konami Services you use.
Your personal data is very important to us. We promise to protect it to the standard required by the Data Protection Laws which apply when we provide Konami Services to you in the EU or the UK.
I am in the EU, tell me more about the laws which protect my personal data
If you are in the EU then we will comply with EU Data Protection Laws including the GDPR (General Data Protection Regulation), the Privacy and Electronic Communications Directive 2002/58/EC as amended and related Member State laws and regulations on data protection and privacy.
I am in the UK, tell me more about the laws which protect my personal data
If you are in the UK then we will comply with UK Data Protection Laws including the Data Protection Act 2018, the UK GDPR (General Data Protection Regulation), the Privacy and Electronic Communications Regulations 2003 as amended and related UK laws and regulations on data protection and privacy.
Our Privacy Promise to you is that when collecting and using your personal data we will do the following:
· Comply: We will respect Data Protection Laws.
· Inform: We will tell you clearly, openly and honestly about the reasons and purposes for collecting and using your personal data.
· Control: We will put you in control of your personal data, by telling you your rights and how to exercise them.
· Secure: We will use strong security measures to keep your personal data safe and secure.
· Trust: We will not use your personal data to make money by providing it to anyone else, or any other purpose which you would not expect us to.
Please click on the headings below if you want to find out more about the types of personal data we collect about you, how we use and protect your personal data, and how you can contact us with any questions or to exercise your rights under Data Protection Laws.
1. How long we keep your data
We will keep your personal data for the periods explained in the information provided through PART I for the particular Konami Services you will use.
If you would like more information on the periods which we keep specific types of your personal data for, then please contact us as explained in Section 8. If you feel that we are keeping your personal data for too long, then in some circumstances you can ask us to stop processing or to delete your data – see Section 7 on your rights and how to exercise them.
2. How we keep your data secure
Keeping your personal data safe and secure is our priority.
As required by Data Protection Laws, we have put in place appropriate ‘technical’ and ‘organisational’ security measures to prevent breaches of your personal data:
- Our ‘technical’ measures for protecting your personal data include ensuring that the data centres in Japan which Konami operates have very strict physical controls for who can access your personal data, strong protections against threats such as cyber-attacks, viruses and power-cuts, and are regularly backed up. When we use third party services for data storage, we ensure that they also use appropriate technical security measures (see Sharing with Service Providers below).
- Our ‘organisational’ measures for protecting your personal data include managing carefully the staff who can access your data. For example, we always make sure that our staff agree to ‘confidentiality obligations’ (meaning they promise to keep your personal data secret) in our employment contracts with them and we train our staff on the importance of protecting your personal data and our obligations under Data Protection Laws. Where necessary, we undertake background checks on our staff to make sure that they are honest and trustworthy, before giving them access to your personal data.
If you would like more information about these security measures, then please contact us as explained in Section 8.
3. What we do if there is a personal data breach
Personal data breaches can include a wide range of incidents which affect the confidentiality, integrity or availability of your personal data. Some breaches result from accidents, others from unlawful actions. Common examples of breaches include where:
- Personal data is lost, destroyed, corrupted or disclosed
- Someone accesses the personal data or passes it on without permission
- The personal data is made unavailable, for example because it has been accidentally lost or destroyed or because it has been damaged by a computer virus
We recognise that security breaches involving your data could cause you distress, financial damage or other harm. We have therefore put in place reporting procedures to respond quickly to any suspected personal data breach and to ensure that our staff are trained on these procedures. Where a personal data breach poses a potentially significant risk to you, then we will notify you and any relevant Data Protection Authority (see Section 9) of a personal data breach in situations where Data Protection Laws require us to do so, so that you can take appropriate steps to protect yourself from the breach.
Where we need to use other businesses to assist us in providing you with Konami Services, then we also require them to implement the same strict standard of security measures and to notify us of any personal data breaches promptly – see Section 5 for more information.
4. Who we share your personal data with
We do not make money by providing your personal data to other businesses. We will share your personal data within the Konami group of companies (Konami Group) and with our service providers in order to provide you with Konami Services that you expect and enjoy. Occasionally, situations may arise where we need to share your personal data with other types of organisations. We explain our sharing of your personal data below. Please see Part I - Section C or contact us using the details in Section 8 for specific information.
Sharing with Konami Group companies
We provide Konami Services to users all over the world. Providing you with Konami Services in your country or region requires us to work closely with other Konami Group companies and to share your personal data with them.
For example, as you are in the EU or the UK then we may need to share your personal data with Konami Group companies in the EU or UK in order to:
- ensure that you are able to access appropriate customer support services for your query
- arrange events held by us or by other Konami Group companies in your country or region that you wish to attend
- manage and update your accounts with us
- analyse the preferences and needs of our users in your country or region in order to improve the quality of Konami Services
- procure data centre services to protect and store your personal data safely
We will only share your personal data with Konami Group companies to provide you with or to improve Konami Services or for other purposes such as for the development or improvement of Konami Group products and services, marketing and promotional purposes, and for Konami Group companies to hold their own events. We will ensure that any Konami Group companies that receive your personal data will only use it as permitted by Data Protection Laws and for the purposes set out in this Notice and (where applicable) the privacy notices of the relevant Konami Group companies.
A list of all of our Konami Group companies is available here https://www.konami.com/corporate/en/subsidiaries/
Sharing with service providers
To provide you with Konami Services we use the services of other businesses, which we call ‘service providers’.
For example, the types of service providers we may use are as follows:
- Providers of cloud storage services
- Providers of customer support services
- Providers of analytics services
- Providers of advertising services
- Providers of marketing platforms services
- Providers of content management services
Whenever we share your personal data with service providers, we will protect it to the standard required by Data Protection Laws. We will undertake checks on the service provider before using them and we will control their use of your personal data in a legally binding contract. This approach allows us to make sure that the service provider:
- Only uses your personal data in accordance with our documented instructions.
- Has strong protections in place to keep your personal data secure and secret
- Is accountable to us legally if they fail to meet these strict standards for protecting your personal data
Please note that the service provider may use your personal data for its own purposes, such as maintenance and improvement of its services, in which case the service provider will be the controller of your personal data. In such cases, the service provider has primary responsibility for the processing of your personal data.
Other sharing
Occasionally, there may be other circumstances in which we need to share your personal data with other businesses or organisations. This may be the case, for example, where:
- We are ordered to share your personal data by a Court, the police, a Government body or another organisation which has the legal power to require us to do so
- Another business buys Konami or the part of our business which provides you with Konami Services
- We reorganise how Konami or the Konami Group operates and provides you with Konami Services
When sharing your personal data in such circumstances, we will continue to protect your personal data by respecting and upholding our strict standards and the strict legal obligations imposed on us.
5. How we protect your data in Japan and other countries outside the EU/UK
Konami is a Japanese company and the personal data we collect from you is stored in secure data centres of our service providers that may be located outside the EU or UK, and we apply strict security measures to protect your personal data, as explained in Section 2.
The Data Protection Laws of Japan have been approved by the EU and by the UK as providing the same high standards of protection as the Data Protection Laws of the EU and UK. Where we transfer your personal data to our service providers in countries other than Japan which are not in the EU or UK, then we will comply with the strict requirements imposed on us by the Data Protection Laws of the EU, UK and Japan to ensure that your personal data remains protected to the same high standards.
Details of the safeguards we have put in place can be obtained by contacting us as explained in Section 8.
6. Links to the services of other businesses
Some Konami Services, such as our websites, allow you to access the websites, content and services of other businesses. For example, you may be able to click on weblinks, plug-ins or applications embedded in our websites which take you to the websites of other businesses, which then collect personal data or other information about you.
We do not control those businesses and we are not responsible for their use of your data or information. If you use links to such services of other businesses, please read their privacy notices to make sure that you are comfortable with how they will collect and use your data and information.
7. Your rights under Data Protection Laws
I want to find out what my rights are
You have various legal rights relating to your personal data, which we explain below. Some of these rights are only available in certain circumstances and will depend upon our lawful basis for using your personal data (which is explained in PART I).
If you make a request to us about your rights then we will provide you with a written response explaining whether we will be able to comply with your request or, if not, the reasons why not.
- Accessing your personal data: You always have the right to ask us to provide you with copies of your personal data. As there are some limitations to this right, sometimes we will not be able to provide you with all of the information you request.
- Correcting your personal data: You always have the right to ask us to correct your personal data if it is not accurate, and to complete your personal data if it is not complete (known as the ‘right to rectification’ under the GDPR).
- Deleting your personal data: In some circumstances, you can ask us to delete your personal data (known as the ‘right to erasure’ or the ‘right to be forgotten’ under the GDPR).
- Restricting our use of your personal data: In some circumstances, you can ask us to restrict our use of your personal data.
- Transferring your personal data: In some circumstances, you can ask us to transfer your personal data to another organisation, or to you, in a format that is generally used for storing and accessing such data (known as the ‘right to data portability’ under the GDPR). This right only applies where you have provided us with your personal data and, in addition, where our lawful basis for using your personal data is either your Consent or is Contract (see PART I – Section C).
- Objecting to our use of your personal data: In some circumstances, you can say you do not agree with our use of your personal data (known as the ‘right to object’ under the GDPR). This right applies where our lawful basis for using your personal data is Legitimate Interests (see PART I – Section C). If we receive a request from you objecting to our use of your personal data, then in general we must stop using it. We may continue to use it only if we have a strong reason to do so and our continued use does not create an unacceptable risk to you. If your objection is to direct marketing, then we must always stop.
- Withdrawing your consent: Where our lawful basis for using your personal data is consent, then you always have the right to change your mind and withdraw your consent (see PART I – Section C).
- No automated decision making or profiling: Data Protection Laws also provide you with a right not to have your personal data used to make decisions about you based on profiling or other forms of automated processing which could affect you legally or in any other similarly significant way. We will never use your personal data for such purposes.
I want to find out how to exercise my rights
- How to contact us: You can exercise your rights by contacting us by email at: privacynotice@faq.konami.com. Alternatively, you can contact us using the details set out in Section 8.
- How long it will take to respond: We try to respond to all personal data requests within one month. Occasionally it may take us longer than a month, if your request is particularly complex or you have made a number of requests. As explained above, please note that there are exceptions to your rights and some situations where they do not apply.
- Additional information about you: We may need to ask for additional information from you to help us confirm your identity. This is a security measure to ensure that personal data is not given to any person who has no right to receive it. We may also contact you to ask you to clarify your request.
- Usually no fee applies: You will not normally have to pay to access your personal data or to exercise any of your other rights. In some circumstances, however, we may charge a reasonable fee if we consider that you are making requests which are especially unreasonable. For example, if you make an unreasonably large number of requests or request an unreasonably large amount of information. Alternatively, we may refuse to comply with your request in these circumstances.
8. How to contact Konami with questions
There are several ways in which you can contact us with any questions about our use of your personal data, or to exercise your rights under Data Protection Laws. These are explained below:
- Contact us: You can contact us at: privacynotice@faq.konami.com
- Contact our Data Protection Officer: We have appointed a Data Protection Officer (DPO), who has overall responsibility for looking after the Konami Group’s compliance with Data Protection Laws. You can contact our DPO by emailing them at: dpo-team@konami.com
- Contact our EU Representative: If you are in the EU and would prefer to contact our local EU representative, you can do so by emailing the French Branch of Konami Digital Entertainment B.V. at rep-gdpr@konami.info
- Contact our UK Representative: If you are in the UK and would prefer to contact our local UK representative, you can do so by emailing the UK Branch of Konami Digital Entertainment B.V. at rep-gdpr@konami.info
If you have any general inquiries about Konami Services, you can contact us by emailing at: https://www.konami.com/games/inquiry/
9. How to complain to a Supervisory Authority
We value our relationship with you and want to ensure that you are comfortable with how we use your personal data to provide you with Konami Services. If you feel that we have failed to look after your personal data properly, or have misused it, then we would always encourage you to contact us first as we will do our best to resolve the issues for you. You can contact us using the details in Section 8.
Alternatively, you have the right to make a complaint to a ‘Supervisory Authority’ (the government regulator for data protection) about our use of your personal data:
- EU DPA: If you are in the EU, you can find the Supervisory Authority for your country and how to contact them here: https://edpb.europa.eu/about-edpb/board/members_en
- UK DPA: If you are in the UK, the Supervisory Authority is the Information Commissioner’s Office, who you can contact here: https://ico.org.uk/make-a-complaint/your-personal-information-concerns/
10. Changes to this Notice
We may make changes to this Notice from time to time.