PRIVACY NOTICE
This privacy notice is issued by Konami Digital Entertainment Co., Ltd. (hereinafter referred to as "Konami”, “we”, “our”, or “us”), a company based at 1-11-1 Ginza, Chuo‐ku, Tokyo 104-0061 Japan.
When you participate in the eFootball™ Point Program ("Program"), we will use your personal data as specified below.
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 Konami” 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 our website [https://legal.konami.com/games/efbpp/en-gb/].
1. Our use of your personal data
2. Our sharing of your personal data with other companies
3. How we protect your data in Japan and other countries outside the EU/UK
4. Your rights and requests to Konami
5. Our security for your personal data
6. How to contact Konami with questions
1. Our use of your personal data
We process your personal data in accordance with applicable European Union (“EU”) and United Kingdom (“UK”) laws, regulations, codes of conduct and guidance on data protection and privacy (“Data Protection Laws”), in particular:
· If you are in the EU, then we will comply with the General Data Protection Regulation (EU) 2016/679 ("GDPR"), the Privacy and Electronic Communications Directive 2002/58/EC (as amended) and related EU Member State laws and regulations.
· If you are in the UK, then we will comply with the Data Protection Act 2018, the UK GDPR (being the GDPR as retained in UK law after Brexit), the Privacy and Electronic Communications Regulations 2003 and related statutory Codes of Conduct including the Children’s Code.
Your personal data may be used in order for us to provide you with the service of the Program.
Please note that where we refer in this privacy notice to:
· “personal data”, this means any information which relates to you as an identifiable individual; and
· the “EU”, this also includes the European Economic Area (“EEA”) Member States of Norway, Iceland and Liechtenstein.
Categories of personal data we collect
Below are the categories of personal data that we collect when you participate in the Program. Unless otherwise stated below, personal data in parenthesis are examples of the data we collect.
< Purpose for processing of the personal data (“Purpose”)>
(a)To operate, manage, and provide the Program
(b) To provide you the eFootball™ Points you earned
(c)To provide you virtual item(s) that you have exchanged with your eFootball™ Points
(d)To invalidate your expired eFootball™ Points
(e)To improve the quality of the Program and our games/services
(f) To generate the statistical data (including generating of the statistical data to be provided to the third parties)
< Categories of personal data to be processed>
Identifiers (User ID of the game, KONAMI ID, password for KONAMI ID, Application unique ID), Customer Data (Contact Info such as email address registered to KONAMI), Usage Data (Country, State, Language, player name (online ID* /owner ID), value of your valid eFootball™ Points, records related to eFootball™ Points**)
* If you participate in the Program from a PS4/PS5 console version of the game then we will obtain your online ID for the platform that you use to play the game from the relevant online platform provider, Sony.
** “Records related to eFootball™ Points” in the Categories of Personal Data include any process of the eFootball™ Points (e.g., increase, decrease and expiry), the date and time of such processes, and the number of eFootball™ Points processed, ID of any earned or consumed virtual item, information of the application the Program was accessed from, User ID of the game and KONAMI ID, etc..
< Lawful Basis for processing of the personal data>
Legitimate Interest
This means our interest in operating our business to provide various merits to the participant of the Program and show our gratefulness to such participants’ interest to our football related product/services, as set out in more detail for each of the Purposes above. 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 Section 4). To find out more, please contact us as explained in Section 6.
< Retention Period of the personal data>
We keep your personal data as long as necessary to ensure that we can continue to offer you the Program until:
(i) you ask us to delete your personal data that is processed for our service of the Program, or
(ii) the provision of our service of the Program 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 services of the Program.
2. Our sharing of your personal data with other companies
We share personal data with other companies to run and hold the Program, as well as to protect our business interests. Occasionally, situations may arise where we need to share your personal data with other types of organisations. We explain below our sharing of your personal data, and please contact us using the details in Section 6 if you have specific questions.
(a) Sharing with our group companies
We share personal data with other companies in the Konami group (“Konami Group”) where necessary to hold and run the Program.
We may also share personal data within Konami Group for them to report activities of Konami Group companies for PR (including investor relations) purposes.
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 privacy notice and (where applicable) the privacy notices of the relevant Konami Group companies.
A list of all of our Konami Group companies is available at https://www.konami.com/corporate/en/subsidiaries/.
(b) Sharing with service providers
We also share personal data with service providers outside the Konami Group where necessary for the purposes explained in Section 1. Whenever we share your personal data with service providers, we will protect it to the standard required by Data Protection Laws by undertaking checks on the service provider before using them and controlling their use of your personal data in a legally binding contract. Below are the categories of third parties with which we share personal data.
https://legal.konami.com/kde/processor-list/
(c) Sharing with other entities
We may also share your personal data with other entities not specified above (i) in the event of a restructuring, sale or merger of the Konami business or company which relates to the Program or (ii) if it is requested by judicial, administrative, or other public authorities (including authorities outside your district of residence).
In every case, we will only share your personal data to the minimum extent necessary for the specified purpose and we shall ensure that appropriate safeguards are in place to ensure the security and confidentiality of your personal data in accordance with Data Protection Laws.
3. 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 operated by the Konami Group and by its service providers in Japan and in other countries including the United States, and we apply strict security measures to protect your personal data, as explained in Section 5.
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 6.
4. Your rights and requests to Konami
Your rights and how to exercise them
You have the following rights that you can exercise with Konami.
- 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. As there are some limitations to this right, sometimes we will not be able to provide you with all of the information you request.
- Correction or erasure of personal data: In some circumstances, you have the right to require Konami to correct inaccurate personal data that concerns you without undue delay and to complete any incomplete personal data. You may also have the right to require Konami to erase the personal data that concerns you without undue delay, when certain legal conditions apply.
- Restriction on processing of personal data: You may have the right to require Konami to restrict the processing of personal data, when certain legal conditions apply.
- Portability of personal data: You may ask us to transfer your personal data to another organisation, or to you, in a systematic format available for general use, so that the data may be shared with another company, when certain legal conditions apply.
- 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. This right applies where our lawful basis for using your personal data is ‘legitimate interests’. 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.
- Not to be subject to automated decision-making: You may have the 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, when certain conditions apply We will never use your personal data for such purposes.
- 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.
You can exercise these rights by contacting us using the details in Section 6 below. Please note the following points:
- Response time: 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: 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: 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.
Your right 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 in relation to the Program. 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 6.
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:
- 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
- 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/
5. Our security for your personal data
(a) 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.
- 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.
(b) 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.
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 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.
6. 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:
- You can use these rights by contacting us at the following link: 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