PART II. GENERAL INFORMATION

This PART II provides more general information about how we process your Personal Data to those residing in the countries and regions other than Japan or the U.S..

Please note that Local Addendum(s) attached to this Notice as the Exhibit(s) (Local Addendum) provides information specific to each of the countries and regions specified therein. IF YOU ARE A RESIDENT OF ANY COUNTRY OR REGION IDENTIFIED IN THE LOCAL ADDENDUM, MAKE SURE TO READ THE LOCAL ADDENDUM APPLICABLE TO YOU.

You can click on the link below to jump to the Local Addendum.

EEA/UK LOCAL ADDENDUM

KOREA LOCAL ADDENDUM

Your Personal Data is very important to us. We promise to protect it to the standard required by Data Protection Laws which apply when we provide Konami Services to you.

I want to know more about Konami

Konami Digital Entertainment Co., Ltd. is a Japanese company which specialises in developing ‘online’ and ‘offline’ games, such as computer, console and mobile app games, trading card games, and related music and video content. We also organise events and competitions related to these games. We are based in Tokyo, Japan and our company’s main office address is 1-11-1 Ginza, Chuo-Ku, Tokyo 104-0061, Japan. You can find out how to contact us in Section 5. More information about us is on our website: https://www.konami.com/games/corporate/en/

1. Privacy Policy

We will process your Personal Data in accordance with our Privacy Policy [https://legal.konami.com/kde/global/en-gb/], which includes more detailed explanations of:

· the technical and organisational security measures we implement to protect Personal Data;

· how we manage contractors who process Personal Data on our behalf;

· how we handle incidents and breaches relating to Personal Data; and

· how we ensure that international transfers of Personal Data are compliant with Data Protection Laws.

2. How long we keep your data

We will keep your Personal Data for the periods explained in PART I for the particular Konami Services you will use.

If you would like more information on the periods which we keep specific types of your Personal Data for, then please contact us as explained in Section 5.

3. Who we share your Personal Data with

We do not make money by providing your Personal Data to other businesses. We will share your Personal Data within the Konami group of companies (Konami Group) and with our service providers in order to provide you with Konami Services that you expect and enjoy. Occasionally, situations may arise where we need to share your Personal Data with other types of organisations. We explain our general sharing of your Personal Data below. Please see Part I or contact us using the details in Section 5 for specific information.

Sharing with Konami Group companies

We provide Konami Services to users all over the world. Providing you with Konami Services in your country or region may require us to work closely with other Konami Group companies and to share your Personal Data with them.

For example, we may need to share your Personal Data with Konami Group companies in order to:

- ensure that you are able to access appropriate customer support services for your query.

- arrange events held by us or by other Konami Group companies in your country or region that you wish to attend.

- manage and update your accounts with us.

- analyse the preferences and needs of our users in your country or region in order to improve the quality of Konami Services.

- procure data centre services to protect and store your Personal Data safely.

Unless otherwise explained in PART I, we will only share your Personal Data with Konami Group companies to provide you with or to improve Konami Services or for other purposes such as for the development or improvement of Konami Group products and services, and marketing and promotional 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 Notice and (where applicable) the privacy notices of the relevant Konami Group companies.

A list of all of our Konami Group companies is available here https://www.konami.com/corporate/en/subsidiaries/

Sharing with service providers

To provide you with Konami Services we use the services of other businesses, which we call ‘service providers’.

For example, the types of service providers we may use include:

- Providers of cloud storage services

- Providers of customer support services

- Providers of analytics services

- Providers of advertising services

- Providers of marketing platforms services

- Providers of content management services

Whenever we share your Personal Data with service providers, we will protect it to the standard required by Data Protection Laws, as further explained in our Privacy Policy.

Other sharing

Occasionally, there may be other circumstances in which we need to share your Personal Data with other businesses or organisations. This may be the case, for example, where:

- We are ordered to share your Personal Data by a Court, the police, a Government body or another organisation which has the legal power to require us to do so

- Another business buys Konami or the part of our business which provides you with Konami Services

- We reorganise how Konami or the Konami Group operates and provides you with Konami Services

When sharing your Personal Data in such circumstances, we will continue to protect your Personal Data by respecting and upholding our strict standards and the strict legal obligations imposed on us.

4. Links to the services of other businesses

Some Konami Services, such as our websites, allow you to access the websites, content and services of other businesses. For example, you may be able to click on weblinks, plug-ins or applications embedded in our websites which take you to the websites of other businesses, which then collect Personal Data or other information about you.

We do not control those businesses and we are not responsible for their use of your data or information. If you use links to such services of other businesses, please read their privacy notices to make sure that you are comfortable with how they will collect and use your data and information.

5. How to contact Konami with questions

You can contact us with any questions about our use of your Personal Data, or to exercise your rights under Data Protection Laws at: privacynotice@faq.konami.com

If you have any general inquiries about Konami Services, you can send us them from: https://www.konami.com/games/inquiry/

There may be other ways to contact us depending on where you reside. Please refer to the Local Addendum applicable to you for more information.

6. Changes to this Notice

We may make changes to this Notice from time to time.


EXHIBIT A – LOCAL ADDENDUM

(EEA/UK)

This EEA/UK Local Addendum provides information specific to those residing in the EEA/UK. IF YOU DO NOT LIVE IN THE EEA NOR THE UK, THIS EEA/UK LOCAL ADDENDUM DOES NOT APPLY TO YOU.

I want to know more about what “your Personal Data” means

When we refer to “Personal Data” we mean any information which relates to you as an identifiable individual. A wide range of information can be your “Personal Data”. Some examples you would expect are your name, email address, home address and telephone number. Some less obvious examples include your gameplay history and the fact that you have won prizes in our competitions. We explain in PART I the Personal Data which we may collect about you, depending on the type of Konami Services you use.

I am in the EU, tell me more about the laws which protect my Personal Data

If you are in the EU then we will comply with EU Data Protection Laws including the GDPR (General Data Protection Regulation), the Privacy and Electronic Communications Directive 2002/58/EC as amended and related Member State laws and regulations on data protection and privacy.

I am in the UK, tell me more about the laws which protect my Personal Data

If you are in the UK then we will comply with UK Data Protection Laws including the Data Protection Act 2018, the UK GDPR (UK General Data Protection Regulation), the Privacy and Electronic Communications Regulations 2003 as amended and related UK laws and regulations on data protection and privacy.

1. Legal bases.

Legitimate Interests: this means our interest in providing you with Konami Services, which is further explained in PART I. Where we rely on legitimate interests, 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 2 below). To find out more, please contact us as explained in PART II or in Section 4 below.

Contract: this means we use your Personal Data where we need to so that we can do what we have promised to you (such as providing in-game purchases), or you have promised to 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). If you do not permit such uses of your data we may not be able to provide services to you.

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 Section 2 below), 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.

2. Your rights under Data Protection Laws

I want to find out what my rights are

You have various legal rights relating to your Personal Data, which we explain below. Some of these rights are only available in certain circumstances and will depend upon our legal basis for using your Personal Data (which is explained in PART I).

If you make a request to us about your rights then we will provide you with a written response explaining whether we will be able to comply with your request or, if not, the reasons why not.

- Accessing your Personal Data: You always have the right to ask us to provide you with copies of your Personal Data. As there are some limitations to this right, sometimes we will not be able to provide you with all of the information you request.

- Correcting your Personal Data: You always have the right to ask us to correct your Personal Data if it is not accurate, and to complete your Personal Data if it is not complete (known as the ‘right to rectification’ under the GDPR).

- Deleting your Personal Data: In some circumstances, you can ask us to delete your Personal Data (known as the ‘right to erasure’ or the ‘right to be forgotten’ under the GDPR).

- Restricting our use of your Personal Data: In some circumstances, you can ask us to restrict our use of your Personal Data.

- Transferring your Personal Data: In some circumstances, you can ask us to transfer your Personal Data to another organisation, or to you, in a format that is generally used for storing and accessing such data (known as the ‘right to data portability’ under the GDPR). This right only applies where you have provided us with your Personal Data and, in addition, where our legal basis for using your Personal Data is either your Consent or is Contract (see PART I).

- Objecting to our use of your Personal Data: In some circumstances, you can say you do not agree with our use of your Personal Data (known as the ‘right to object’ under the GDPR). This right applies where our legal basis for using your Personal Data is Legitimate Interests (see PART I). 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.

- Withdrawing your consent: Where our legal basis for using your Personal Data is consent, then you always have the right to change your mind and withdraw your consent (see PART I).

- No automated decision making or profiling: Data Protection Laws also provide you with a 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. We will never use your Personal Data for such purposes.

I want to find out how to exercise my rights

- How to contact us: Konami is the controller of your personal data and you can exercise your rights by contacting us by email at: privacynotice@faq.konami.com. Alternatively, you can contact us using the details set out in PART II or Section 4 below.

- How long it will take to respond: 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 about you: 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 applies: 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.

3. International Data Transfers

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 (see the processor list for details: https://legal.konami.com/kde/processor-list/). The Data Protection Laws of Japan have been approved by the EU and by the UK as providing adequate protection for your Personal Data to the same high standards as the Data Protection Laws of the EU and UK.

Where we transfer your Personal Data to Konami Group companies and to our service providers which are located in countries outside Japan, the EU and the UK that are not recognised under EU and UK Data Protection Laws as providing such adequate protection, then we will comply with the strict requirements imposed on us by such laws to implement appropriate safeguards for protecting your Personal Data adequately. In most cases, we achieve this by entering into data transfer agreements incorporating Standard Contractual Clauses approved under EU and UK Data Protection Laws as appropriate safeguards for protecting your Personal Data.

Details of the safeguards we have put in place can be obtained by contacting us as explained in PART II or Section 4 below.

4. How to contact Konami with questions

In addition to those explained in PART II, you can contact us as explained below:

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

5. How 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 to provide you with Konami Services. 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 PART II or Section 4 above.

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:

- EU DPA: 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

- UK DPA: If you are in the UK, the Supervisory Authority is the Information Commissioner’s Office, which you can contact here: https://ico.org.uk/make-a-complaint/your-personal-information-concerns/


EXHIBIT B – LOCAL ADDENDUM

(KOREA)

This Korea Local Addendum provides information specific to those residing in the Republic of Korea (Korea). IF YOU DO NOT LIVE IN KOREA, THIS KOREA LOCAL ADDENDUM DOES NOT APPLY TO YOU.

1. Definitions

For the purpose of this Korea Local Addendum, the following terms shall have the following meanings.

- Third Party means any third party excluding our service providers (explained in PART II. Section 3).

- Delete or Deletion means to erase, delete, and dispose of your Personal Data.

- Expired Data means your Personal Data the retention period of which have expired or that is no longer necessary for us.

- Data Rights means your rights under the Korean Data Protection Laws to request Konami to disclose, correct, delete, or cease the processing of your Personal Data.

- Data Request means your request to Konami based on the Data Rights.

2. Personal Data we process

We process your Personal Data as explained in PART I.

3. Transfers of your Personal Data to a Third Party and our service providers outside Korea

Providing your Personal Data to a Third Party

We process your Personal Data only for the purposes explained in PART I. Section A - 2 and will not provide your Personal Data to any Third Party unless we obtain your consent required under the Korean Data Protection Laws or as otherwise permitted thereunder. In case where we provide your Personal Data to any Third Party, we will disclose information regarding such Third-Party provision or your Personal Data in this Korea Local Addendum as required under the Korean Data Protection Laws.

Providing your Personal Data to our service providers outside Korea

We may provide your Personal Data to our service providers which may be located outside Korea. The location and other details of our service providers can be found at PART I. Section C-2.

4. How long your Personal Data are retained and used by us

We retain and use your Personal Data as explained in PART I. Section C-1.

5. How we delete and dispose of your Personal Data

We will Delete your Personal Data upon expiration of the retention period or otherwise when it is no longer necessary for us.

If there are any Legal Obligations requiring us to retain Expired Data for a longer time after the expiration of its retention period, we will retain them separately from other Personal Data, including by transferring Expired Data to another database and retaining them therein.

Procedure of the Deletion

We will determine which Personal Data shall be classified as Expired Data and delete or dispose of such Expired Data after obtaining our Chief Privacy Officer’s approval.

Method of the Deletion

We will destruct any Personal Data retained in electromagnetic form or in print form so that any Personal Data recorded or saved therein cannot be reproduced, including by cutting, burning, or dissolving them.

6. Our team handling privacy-related matters

We have appointed the following team to handle our privacy-related matters, including any privacy-related complaints from the data subjects. You may send us requests based on the Korean Data Protection Laws to the following team.

- Name: KONAMI Customer Support Center

- E-mail: privacynotice@faq.konami.com

7. Your rights and obligations and how to exercise them

Konami shall respond to Your Data Request without undue delay, provided that such Data Request is made in accordance with the Korean Data Protection Laws.

- Data Request may be made either in writing, electronic mail, or facsimile.

- Data Request may be made by your agent, such as your legal guardian or delegatee, provided that you must provide us the document evidencing the fact that you have authorized such person to act on your behalf, as required under the Korean Data Protection Laws.

- Konami will verify your or your agent’s identity prior to responding to Your Data Request.

- Please be noted that:

- there may be restrictions on your Data Rights regarding disclosure and/or cessation of the processing under the Korean Data Protection Laws.

- You may not request us to delete your Personal Data where we have legitimate grounds for collecting such data under any laws other than the Korean Data Protection Laws.

- Konami is obliged under the Korean Data Protection Laws to make it easier for you to request to withdraw your consent for our processing or to disclose or correct your Personal Data than to give consent to the collection of your Personal Data.

8. How to contact our Korea domestic representative

We value our relationship with you and want to ensure that you are comfortable with how we use your Personal Data to provide you with Konami Services. 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 PART II.

Alternatively, you may contact our Korea domestic representative to make a complaint about our use of your Personal Data. Contact information of our Korea domestic representative is as follows.

Name: Lee&Ko (Sang-gon Kim, Managing Partner)

Address: Konami Digital Entertainment's domestic representative, 18th Floor Hanjin Building, 63 Namdaemun-ro, Jung-gu, Seoul 04532, Korea

Phone number: +82-2-6386-7196

e-mail address: privacy_konami@leeko.com