Date last updated: April 9, 2022
If you are a California resident, this Privacy Policy Addendum for California Residents (“California Addendum”) applies to you. We have adopted this California Addendum to comply with the California Consumer Privacy Act of 2018 (“CCPA”) and other California laws. The California Addendum supplements our standard privacy policy and prevails over any conflicting provisions in the standard privacy policy [https://legal.konami.com/games/privacy/en/].
This California Addendum uses certain terms that have the meanings given to them in the CCPA, including:
· “Personal Information,” which means information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household.
· “Sell,” “selling,” “sale,” or “sold,” which means the selling, renting, releasing, disclosing, disseminating, making available, transferring, or otherwise communicating orally, in writing, or by electronic or other means, your Personal Information by us to another business or a third party for monetary or other valuable consideration.
1. Our Collection, Use, and Disclosure of Personal Information
A. Categories, Sources, and Purposes of Your Personal Information Collected or to Be Collected
The table below describes the categories of Personal Information (as listed in the CCPA) that we may collect, and have collected during the 12-month period prior to the effective date of this California Addendum.
| Category of Personal Information Collected | Example |
|---|---|
| Identifiers | Identifiers (user ID, platform authentication token, platform account ID) |
| Additional data subject to the California customer records law (any categories of personal information described in subdivision (e) of Cal. Civ. Code Sec. 1798.80) |
Network information (IP address) Usage data (play data, log, and user data such as language, country or region, platform information, and Steam username) |
Business or Commercial Purposes. The following is a list of the business or commercial purposes for which the categories of Personal Information will be, or was, collected or used during the 12-month period prior to the effective date of this California Addendum:
· To provide the game and its related services (collectively, “Game Service”)
· To improve the quality of, or newly develop, our products and services
· To establish our business strategy
· To detect any suspected violation of our Rules* and determine our appropriate actions against any such suspected violation
*“Rules” means any terms, conditions, regulations and/or any other rules that we have set with regard to your use of our products and services, including but not limited to, the Game Service. Rules 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”.
Categories of Sources. The following is a list of the categories of sources from which Personal Information was collected during the 12-month period prior to the effective date of this California Addendum:
· Yourself
B. Sharing of Your Personal Information
(A) Sale of Your Personal Information
We do not sell Personal Information and have not sold Personal Information during the 12-month period prior to the effective date of this California Addendum, including the Personal Information of minors.
(B) Disclosure of Personal Information for a Business Purpose
The table below describes: (i) the categories of Personal Information (as listed in the CCPA) that we may have disclosed for our operational business purposes during the 12-month period prior to the effective date of this California Addendum; and (ii) the categories of third parties to whom we have disclosed such Personal Information for our operational business purposes during the 12-month period prior to the effective date of this California Addendum.
| Category of Personal Information Disclosed | Example | Third Parties to whom Personal Information Was Disclosed in the Last 12 Months |
|---|---|---|
| Identifiers | Identifiers (user ID, platform authentication token, platform account ID) |
Group companies of Konami Processor - Service providers (cloud service) Processor - Service providers (reseller) |
| Additional data subject to the California customer records law (any categories of personal information described in subdivision (e) of Cal. Civ. Code Sec. 1798.80) |
Network information (IP address) Usage data (play data, log, and user data such as language, country or region, platform information, and Steam username) |
2. Your Rights and Requests
If you are a California consumer, you have certain choices regarding your Personal Information, as described below:
I. Access: You have the right to request, twice in a 12-month period, that we disclose to you the following information we have collected, used, and disclosed about you during the 12 months preceding your request:
(I) The categories of Personal Information we collected about you;
(II) The categories of sources from which we collected such Personal Information;
(III) The business or commercial purpose(s) for collecting such Personal Information about you;
(IV) The categories of third parties with whom we shared such Personal Information; and
(V) The specific pieces of Personal Information we have collected about you.
II. Deletion: You have the right to request that we delete certain Personal Information we collected from you.
How to Submit a Request. To make an access or deletion request (described above), please contact us by any of the following means:
○ Toll-free telephone number: 1-833-929-2977
○ E-mail address: [privacy-ccpa@faq.konami.com]
Verifying Requests. To help protect your privacy and maintain security, we will take steps to verify your identity before granting you access to your Personal Information or complying with your deletion request.
We consider an access or deletion request made through your password-protected account sufficiently verified when the request relates to Personal Information associated with that specific account.
In addition, if you do not have, or cannot access, a password-protected account with us, we will verify an access or deletion request by using the following procedures:
(1) If the relevant product or service has an inquiry function, we will consider the request submitted through the inquiry function to be sufficiently verified. However, if we suspect that the request has been made by someone other than the actual user of the product or service, we will verify your identity by asking you to provide information that only the person who used the product or service may know.
(2) If the relevant product or service has no inquiry function, we will verify your identity by sending a customer number to you through a notification function within the relevant product or service, and requesting that you reply to us with that number. However, if the product or service has no notification function or you cannot use it, we will verify your identity by asking you to provide information that only the person who used the product or service may know.
If you use an authorized agent to make an access or deletion request on your behalf, we may require you to (1) provide the authorized agent signed permission to do so, (2) verify your own identity directly with us (as described above), and (3) directly confirm with us that you provided the authorized agent permission to submit the request.
Additional Information. If you choose to exercise any of your rights under the CCPA, you have the right to not receive discriminatory treatment by us. To the extent permitted by applicable law, we may charge a reasonable fee to comply with your request.
3. Other California Privacy Rights
A. Status of “Do Not Track”
At this time, we are not aware of worldwide uniform or consistent industry standard or definition for responding to, processing, or communicating Do Not Track signals. Accordingly, our website and online services are unable to respond to “Do Not Track” requests from browsers.
In addition, when you visit our website or online services, we and third parties may use tracking technologies to collect your Personal Information about your online activities for a variety of purposes, including serving you advertising, over time and across third-party locations.
B. California “Shine the Light” Law (Civil Code Section § 1798.83)
You have the right to request that we provide information concerning (a) a list of the categories of Personal Information we share with third parties by means of the mail, telephone, or electric mail for their direct marketing purposes during the immediately preceding calendar year, and (b) the name and address of all such third parties free of charge. To make such request, please contact us by e-mail at [privacy-ccpa@faq.konami.com].
4. Changes to this California Addendum
We may change this California Addendum from time to time. The “Date last updated” at the top of this page states when this California Addendum was last updated; any changes will become effective upon us posting the revised California Addendum.
We will post a prominent notice in the product or service to notify you of any significant changes to this California Addendum and indicate the date it was most recently updated.
5. Contact Us
If you have any questions or concerns regarding this California Addendum or our privacy practices, please contact us at:
Konami Digital Entertainment Co., Ltd.
1-11-1 Ginza, Chuo-Ku, Tokyo 104-0061
[Toll-free telephone number: 1-833-929-2977]
[Email address: privacy-ccpa@faq.konami.com]