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/games4gdpr/view/en-gb/.
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.