This Konami Services Privacy Policy Addendum (“Addendum”) is provided by Konami Digital Entertainment Co., Ltd. to comply with the California Consumer Privacy Act of 2018 (“CCPA”) and other California laws, and supplements our standard privacy policy and prevails over any conflicting provisions in the standard privacy policy [https://legal.konami.com/games/privacy/en/].
IF YOU ARE A CALIFORNIA RESIDENT, THIS ADDENDUM APPLIES TO YOU.
This Addendum explains to you how we will use or have used your Personal Information (defined below) in providing you Konami Service (“Konami Service”) during the 12-month period prior to the date last updated (shown above).
Any terms used but is not defined in this Addendum shall have the meanings given to them in the CCPA, including, “Personal Information” and “sale” of the Personal Information.
PART I. SERVICE-SPECIFIC INFORMATION FOR GAMES
Below are the explanations how we use your Personal Information when you play our games (“Game”). For the avoidance of doubt, the Game forms part of Konami Service.
A. GENERAL PROCESSING
1. Collection and Disclosure.
The table below describes the categories of Personal Information (as listed in the CCPA) that we collect in providing you the Game, and whether or not we disclose such Personal Information for our operational business purposes. If we collect or disclose your Personal Information, a checkmark appears in the corresponding box.
Category of Personal Information
Collection
Disclosure
Examples of Personal Information Collected or Disclosed
Identifiers
User identifiers designated by us, such as. user IDs, and those designated by third parties, such as, platform IDs and instance ID for Firebase
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)
· 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.
Characteristics of protected classifications under California or federal law
-
-
N/A
Commercial information
Transaction information, such as records of your in-Game purchases.
Biometric information
-
-
N/A
Internet or network activity information
-
-
N/A
Geolocation data
-
-
N/A
Audio, electronic, visual and similar information
-
-
N/A
Professional or employment-related information
-
-
N/A
Education information subject to the federal Family Educational Rights and Privacy Act
-
-
N/A
Inferences drawn from any of the Personal Information listed above to create profile / summary about, for example, an individual’s preferences and characteristics
-
-
N/A
2. Purposes of our Collection.
We collect your Personal Information explained above for the following purposes.
· To provide you the Game and its related services.
· To improve the quality of Konami Service, including, the Game.
· For our development of new products and services, 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 to 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 defense of legal claims.
· For performance of the contract between us and our business partners (including licensors).
“Rule” means any terms, conditions, regulations and/or any other rules that we have 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”.
3. Categories of Sources.
We collect your Personal Information from the following categories of sources (“Source”).
· Yourself.
· Any devices, networks, and/or game platforms that you use.
4. Third Parties to Whom We Disclosed Your Personal Information.
The list of third parties to whom we disclosed your Personal Information can be found at: https://legal.konami.com/kde/processor-list/
5. Sale of Your Personal Information.
Unless otherwise explained in Section B, we do not sell your Personal Information, including the Personal Information of minors, in providing you the Game.
B. ADDITIONAL PROCESSING
In addition to our general processing explained in Section A., we may process your Personal Information explained below depending on each function and the Game you play have.
Unless otherwise explained in each article, the Source and the third parties to whom we disclose each Personal Information are the same as what we explain in Section A.
1. Mobile Measurements.
Our mobile Game uses or implements either or both of the followings.
Any Personal Information collected for the purposes explained in this article are further referred to in this Addendum collectively as “Mobile Measurement Data”.
a. Adjust Technology
Our mobile Game generally uses 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.
Your Personal Information 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 Information and use them for the promotion and marketing of Konami Service.
· Identifiers, for example, user ID, ad ID, and cookie identifier.
· Additional Information, for example:
· 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.
We sell Mobile Measurement Data to analytics and measurement service providers, for the purposes of marketing and promotion of Konami Service, including, the Game.
2. In-Game Advertisements.
If the Game you play displays in-Game advertisements (“Ads”), we may process categories of Personal Information 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, for example, ad ID.
· Additional Information, for example:
· 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
If your Game serves personalized in-Game Ads, we sell categories of Personal Information explained above to advertising services, for the purpose of serving you personalized in-Game Ads.
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 Information that 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.
We do not sell your Personal Information that we process for this purpose, including the Personal Information of minors.
4. In-Game Incentives.
We sometimes offer in-Game incentives for one Game to the users who have played or are playing 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 are 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 2022 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 2023.
Incentives that we offer generally are not “financial incentives” under the CCPA (“Financial Incentive”). If we ever do offer you any Financial Incentive, we will provide you a separate notice of Financial Incentive in accordance with the CCPA.
We do not sell your Personal Information that we process for this purpose, including the Personal Information of minors.
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 our other products and services, or for the development of new products and services.
We do not sell your Personal Information that we process for this purpose, including the Personal Information of minors.
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 Information related to your use of the Game during such Qualifying Event will be used to run the Event.
Unless otherwise explained in our privacy policies or notices for the Event, we do not sell your Personal Information that we process for this purpose, including the Personal Information of minors.
7. Statistical data.
We may process your Personal Information 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 Information for this purpose, aggregate statistical data shared with our business partners does not and will not include any information that may identify you.
We do not sell your Personal Information that we process for this purpose, including the Personal Information of minors.
