This privacy notice is issued by Konami Digital Entertainment Co., Ltd. (hereinafter referred to as the "Company, we, our or us"), a company based at 1-11-1, Ginza, Chuo-ku, Tokyo, 104-0061 Japan.
The Company provides online games and console games, including the one you are about to play. The way in which we use your personal data when you play our games is very important to us. The Company uses your personal data as described below.
This privacy notice also describes your data protection rights, including the right to object to some of the processing that we carry out. More information about your rights and how to exercise them is set out in the “Your rights and requests to the Company” 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 [https://legal.konami.com/games/pes2020/en-us/].
1. Our use of your personal data
We process your personal data in accordance with the applicable EU and Member State regulations on data protection, and in particular, the General Data Protection Regulation (EU) 2016/679 ("GDPR").
Your personal data may be used in order to help us provide you with our games which you intend to play and any game related services.
The Company processes your personal data for our interests, as well as for your interest, so we provide and you receive the game-related services that you have requested and expect from us (Article 6 (1) (f) GDPR).
Below are the categories of personal data that we collect when you play our game.
| Purpose | Categories of Personal Data | Lawful Basis |
|---|---|---|
| To operate games and game-related events | User ID, user name, country code, country or region, language, play data, competition data, ranking data, replay data, IP address, event participation history, etc. | Legitimate interest |
| To identify users | User ID, country or region, language, terminal ID, play data, IP address, network data, and purchase history | Legitimate interest |
| To improve the quality of our products and services | User ID, terminal identification data, IP address, network data, play data (crash data, game results, disconnection data, etc.), and replay data | Legitimate interest |
| To establish our business strategy | Play data | Legitimate interest |
| To pay fees and perform obligations including record retention under contract with a business partner | Purchase history, terminal ID, country or region, and play data | Legitimate interest |
| To prevent illegal acts |
Data on your machine or terminal and data on your actions (play data etc.) <In case of a PC> User ID, IP address, access date, country code, and terminal information |
Legitimate interest |
To grant in-game benefits to you, the Company also uses the personal data collected from you (user ID and play data) in this game and those related to this game based on the legitimate interest that we pursue (Article 6 (1) (f) GDPR).
We keep your personal data as long as necessary to ensure that we can continue to offer you the game that you intend to play until (i) you ask us to delete your personal data that is processed for our game or game-related services, or (ii) the provision of our game or game-related service 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
- Necessary period for dispute resolution
- Period necessary for performance of the contract
- In the absence of the above, up to 6 months from the end of the service
2. Our sharing of your personal data with other companies
We share personal data with other companies to ensure the quality of our games and services so that we are able to provide you with the game experience you come to expect and enjoy, as well as to protect our business interests.
The Company shares personal data with other companies in the Konami Group (including its affiliates in Japan, Europe, the United States of America, and Hong Kong) (e.g., Konami Business Expert Co., Ltd. (Japan), Internet Revolution, Inc. (Japan), and specifically, those listed at https://www.konami.com/corporate/en/subsidiaries/). In these cases, a Konami Group company that receives your personal data will use the personal data in accordance with this privacy notice and their respective privacy policies.
The Company also shares personal data to service providers (e.g., servers that store data, marketing) or their agencies.
Below are the service providers and their agencies that we share personal data.
| Organisation name | Location |
|---|---|
| Internet Initiative Japan Inc. | Japan |
| Amazon Web Services, Inc. | Germany, Ireland, USA, Brazil, Singapore, Japan |
| Google LLC and its affiliates | USA, Japan, Brazil, UK, Germany, Netherlands, Belgium, Finland, Singapore, Taiwan, India, Australia, Canada |
| Jellymedia Limited | UK |
| E-Sports Media Rights, S.L. | Spain |
| <In case of a PC> Denuvo Software Solutions GmbH |
USA, EEA (European Economic Area) |
We may also share your personal data with other entities not specified above upon (i) the restructuring or other disposition of all or any portion of our business, assets, or stock or (ii) after a request from judicial, administrative, or other governmental authorities (including authorities outside your district of residence).
In every case, we have appropriate safeguards in place to ensure the security and confidentiality of your personal data.
3. Transfer of your personal data to other countries
The Company may send your personal data to other companies outside your country. In particular, if you live in the European Economic Area (EEA), your personal data may be transferred to companies located outside the EEA. When this is the case, either (i) the countries in which those companies are located have been deemed to provide an adequate level of protection for personal data by the European Commission, or (ii) with respect to transfers to companies located in the US, those companies are part of the US Privacy Shield, or (iii) the Company has adopted and implemented Standard Contractual Clauses to oblige the company that receives your personal data to use it fairly and legally.
The Company will provide details of the safeguards to you upon request.
4. Your rights and requests to the Company
You have the following rights that you can use with the Company.
- Information regarding your data processing: You have the right to obtain from us all the requisite information regarding our data processing activities that concern you (Articles 13 and 14 GDPR).
- 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 (Article 15 GDPR).
- Rectification or erasure of personal data: You have the right to have us correct inaccurate personal data that concerns you without undue delay and to complete any incomplete personal data (Article 16 GDPR). You may also have the right to have us erase the personal data that concerns you without undue delay, when certain legal conditions apply (Article 17 GDPR).
- Restriction on processing of personal data: You may have the right to have us restrict the processing of personal data, when certain legal conditions apply (Article 18 GDPR).
- 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 (Article 21 GDPR).
- Not to be subject to automated decision-making: You may have the right not to be subject to automated decision-making (including profiling) based on the processing of your personal data, insofar as this produces legal or similar effects on you, when certain conditions apply (Article 22 GDPR).
You can use these rights by contacting us at:
privacynotice@faq.konami.com
You can contact our Data Protection Officer at:
dpo-team@konami.com
If you believe we have misused your data or violated any data protection regulations, you may file a complaint with a Data Protection Authority, for example, the Authority of your place of residence within the EEA.
If you have any inquiries concerning our products or services, please contact us at the following address:
https://www.konami.com/games/inquiry/