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(s)), how we collect, use, and protect your Personal Data.

In this Notice, Personal Data means your Personal Data or personal information, as further defined in the data protection or privacy laws applicable to you (Data Protection Laws).

Part I provides information specific to the Konami Service that you use. Unless otherwise expressly stated, information provided in Part I applies to all users, regardless of where each user resides.

Part II provides general information on Data Protection Laws, regardless of which Konami Service you use.

Each Local Addendum attached hereto as an Exhibit provides specific additional information required by the relevant country or region, which are currently: (Exhibit A) EEA/UK; (Exhibit B) Korea.

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/id/].

If there is any ambiguity, inconsistency or conflict between the information set out in this Part I, in Part II or in a Local Addendum then, when interpreting the relevant information, it should be interpreted so that the information set out in the Local Addendum takes priority over the information in this Part I which in turn takes priority over the information in Part II.

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.

Below are the categories of your Personal Data we may process when you use “KONAMI ID”, the authentication service provided by Konami (ID Service). For the avoidance of doubt, ID Service forms part of Konami Service.

· Customer data, such as your e-mail address, date of birth, and gender.

· Identifiers, such as user identifiers designated by us (KONAMI ID), password, and identifiers designated by third-party services, for example if you use your ID for social networking services to log-in to ID Service, we will be processing such ID.

· Network information, such as IP address and user agent.

· 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 ID Service, such as selected language, country or region, and profile name.

- Browsing history

- Log

- Fraud prevention information: any data necessary for us to prevent unauthorized or fraudulent use of ID Service.

Below are the purposes for which we may process your Personal Data.

· To provide ID Service and its related services to you.

· For registration and recovery of your KONAMI ID.

· To comply with legal obligations or respond to legitimate requests from public authorities (Legal Obligations).

· For dispute resolution, including the establishment, exercise or defence of legal claims (Dispute Resolution).

· For performance of the contract between us and our business partners (including licensors) (Contract Performance).

We may ask you to log-in to ID Service in various occasions, such as while you are playing our games or when you apply to participate in the events we hold. We then ask you to provide your information (Information) after you have logged-in.

We collect your Information through your use of ID Service, then ID Service transfers such Information to other Konami Service on an as-needed basis, to centrally manage your Information. That way, you will not have to provide us the same Information over and over again.

Below are the categories of Personal Data that ID Service collects for other Konami Service.

· Customer data, such as your name, e-mail address, address, date of birth, phone number, and gender.

· Identifiers, such as user identifiers designated by us (KONAMI ID and user ID) and password.

· Device information, such as operating system.

· Network information, such as IP address.

· Usage data, such as the following.

- User data: such as selected language, and country or region.

- Log

Below are the purposes for which other Konami Service use your Personal Data explained above.

· To provide you with the Konami Service, including:

- to register you as a participant in our closed beta testing;

- for your pre-registration to new Konami Service; and

- to authenticate you when you wish to access your game data saved within our server from a new device.

· For operations necessary for the online and offline event(s) that you choose to participate in (Event), including:

- to register you as the Event participant;

- to contact you about the Event or other related events; and

- to run the Event.

· To send you tangible items, such as the things you have purchased, won, or earned.

· To improve the quality of Konami Service.

· To develop new Konami Service.

Upon your consent, we may process your Personal Data explained below to promote other Konami Service to you by sending you promotional e-mail and by serving ads using third-party ad services (Promotion).

· Customer data, such as e-mail address.

· Status of your consent (whether you have consented to the Promotion or not).

· Information on your activities after you have logged-in to ID Service, such as playing a game, participating in the Event, and using or earning in-game points.

We may provide your Personal Data explained above to third-party ad services, such as those provided by Google, Facebook, and Twitter (Ad Service) for the Promotion. In this case, Ad Service may profile you to effectively serve our ads to our users that are likely to be interested in our Konami Service.

However, we will ask for your separate, explicit consent before providing your Personal Data to Ad Service, as required under the Data Protection Laws.

Konami has implemented parental control features in ID Service to allow Konami Service to appropriately handle children’s Personal Data. This will also help parents and legal guardians manage their children’s online activities.

For more about parental control features of ID Service, visit here: [https://my1.konami.net/en_GB/support/child-account]

The categories of Personal Data that we collect is the same as explained in Section A above, however, the following information will be mandatory when you use parental control features.

· To register and use KONAMI ID that can manage KONAMI ID for your child:

Name, date of birth, address, phone number, country of residence, e-mail address, profile name, KONAMI ID, password, and language.

· To register and use KONAMI ID for your child:

Date of birth, profile name, KONAMI ID, and password

For purposes explained in Sections A and B, we keep your Personal Data for five (5) years after your last log-in to ID Service, thereafter we will erase, delete, and dispose of your Personal Data unless we have to retain it for a longer period of time for Legal Obligation, Dispute Resolution, or Contract Performance.

However, please be noted that each Konami Service will retain the Information for a different period after it receives such Information. Please refer to the privacy notices of each Konami Service for more information.

This section is provided only for those residing in the EEA/UK.

We rely on ‘legitimate interests’ to process your Personal Data for all of the purposes explained in this Part I with the exception of Promotion. This means our interest in operating our business to deliver high-quality Konami Services in the most enjoyable and secure way for you.

In respect of Promotion, we rely on your ‘consent’ to process your Personal Data, which means we have obtained your agreement (or that of a parent/guardian on your behalf) after providing you with enough information in advance for you to make up your mind.

If you would like to know what legal bases are and what rights you have as a result, see the EEA/UK Local Addendum attached to Part II for further information.