When you use or visit our website, we may collect the following Information:

• 1.

  Your browsing history (including the number of times and the duration of time that you visit our website, and the data that identifies the pages you visited prior to and after you visit our website), your internet usage environment (including device identification data and browser type), your IP address, location data derived from your IP address, and language selection used to browse our website.

• 2.

  When you contact any of the contact addresses on our website, we collect Information you provide, including your name, address or other contact information, content of the request, content of the response, and other information needed for subsequent continued response.

• 3.

  We may receive information about you or your device from other sources, such as our affiliates’ websites, our affiliates’ channels for products and services, joint marketing partners, social media platforms (including from people with whom you are friends or otherwise connected) and from other third parties.

Our website uses cookies and other technologies for various purposes, including to distinguish you from other users. This helps us to provide you with a good experience when you browse our website and also allows us to improve our website, and display advertisements which are relevant to your interests. For detailed information on the cookies we use and the purposes for which we use them, please read the Cookie Notice.

Information Use

We may use collected Information for the following purposes:

• 1)

  To permit you to use our website and to provide you with related customer service.

• 2)

  To analyze traffic to our website.

• 3)

  For our business purposes, such as data analysis, enhancing, improving or modifying our website, identifying usage trends, determining the effectiveness of our promotional campaigns and operating and expanding our business activities.

• 4)

  To understand your and other users’ preferences.

• 5)

  To respond to questions and inquiries from you.

• 6)

  To improve our website.

• 7)

  As we believe to be necessary or appropriate, under applicable law, including laws outside your country of residence: (a) to comply with legal process; (b) to respond to requests from public and government authorities, including public and government authorities outside your country of residence; (c) to enforce our terms and conditions; (d) to protect our operations or those of any of our affiliates; (e) to protect our rights, privacy, safety or property, and/or that of our affiliates, you or others; and (f) to allow us to pursue available remedies or limit the damages that we may sustain.

Information Disclosure

As a rule, we do not provide Information to third parties, except in cases where you have given consent; in cases set forth herein; in cases where the Information is to be disclosed in connection with an organizational restructuring or other disposition of all or any portion of our business, assets or stock, including in connection with any bankruptcy or similar proceedings (in which case your Information will be one of the assets which is transferred between Konami Group companies, as defined below, for the purpose of any such restructuring, or may be disclosed and/or transferred to a prospective or actual purchaser of all or any part of our business); in cases where KCM NY is required to disclose the Information by law (including laws outside your country of residence); or in cases where disclosure is requested by a judicial, administrative or other government authority (including an authority outside your country of residence).

We may provide Information to our affiliates or to any third parties for the uses described above, as well as for use when sending notices of campaigns or other events they are planning or holding, or when they are providing advertising, publicity, and marketing tailored to your tastes and interests.

We may also share Information as we believe necessary or appropriate: (1) to enforce our terms and conditions; (2) to protect our operations, rights, privacy, safety or property and/or that of our affiliates, you or others; or (3) to allow us to pursue available remedies or limit the damages that we may sustain.

KCM NY shares Information, for the purposes specified herein, with members of the Konami Group (i.e., companies in which Konami Corp. has a direct or indirect stake, specifically, those listed in https://www.konami.com/corporate/en/subsidiaries/). In such cases, Konami Group companies that receive Information will use and manage the Information in accordance with this Policy.

KCM NY may from time to time provide Information we collect from you to service providers with whom we contract to help us to achieve the purposes specified herein. Our service providers may provide, for example, such services as advertising and publicity and data analysis. We will only share your personal Information (such as your email address) with third parties if you have given us your consent to do so or as described herein.

This Policy does not address, and we are not responsible for, the privacy, information or other practices of any third parties, including any third party operating any website or service to which our websites or services link. In addition, we are not responsible for the information collection, use, disclosure or security policies or practices of other organizations, such as Facebook, Apple, Google, Microsoft, RIM or any other app developer, app provider, social media platform provider, operating system provider, wireless service provider or device manufacturer.

I. Cross-Border Transfer

KCM NY may from time to time store and process Information collected from you on servers located in countries outside your country of residence, even when we store and process the Information ourselves. In particular, if you reside in the European Economic Area, your Information may be transferred to servers located in a non-EEA country where the Information may be handled in accordance with laws which may differ from those of your country. By using or visiting our website, you consent to such transfer of your Information.

II. Information Security

KCM NY seeks to use appropriate and reasonable security measures to protect your Information within our organization. Unfortunately, no data transmission or storage system can be guaranteed to be 100% secure. If you believe that your interaction with us is no longer secure, please immediately notify us at the contact information provided in this Policy.

We do not provide Information to third parties, except in cases where you have given consent and except in cases listed in this Policy.

III. Access Requests

If you would like to access, or you wish KCM NY to correct, delete, or stop using Information collected from you, please make your request in accordance with the following procedures:

If you have any questions, would like to receive a copy of the Information we hold about you, or believe we are holding inaccurate Information about you, or would like us to delete or correct the Information we hold about you, you can contact us at info@konamicrossmedia.com. Please note that requests for access to your Information may be subject to a fee to meet our costs, to the extent a fee is permitted by applicable law.

We may need to verify your identity before implementing your request. We will try to comply with your request as soon as reasonably practicable. Please note that we may need to retain certain information for recordkeeping purposes and/or to complete any transactions that you began prior to requesting a change or deletion. There may also be residual information that will remain within our databases and other records, which will not be removed.

You can opt-out of receiving emails from us by following the “unsubscribe” link in emails from us.

Please note, however, that if the owner of the Information in question cannot be identified, or due to other circumstances, we may not be able to comply with your request. Furthermore, if you request that KCM NY delete or stop using Information needed to provide our services, we may no longer be able to provide you with services.

If you would like to receive a copy of the Information we hold about you, please note that an administration fee may be applicable, to the extent that such a fee is permitted by applicable law.

IV. Your California Privacy Rights

If you are a California resident, you have the right to request certain information regarding our disclosure of your Information to third parties for direct marketing purposes pursuant to Section 1798.83 of the California Civil Code and/ or the California Consumer Privacy Act of 2018 (the “CCPA”).

• a.

  California’s “Shine the Light” Law

If you are a California resident, you have the right to request certain information regarding our disclosure of your Information to third parties for direct marketing purposes pursuant to Section 1798.83 of California Civil Code. If you request such information, please email us at info@konamicrossmedia with “California Privacy Rights” in the subject line.

• b.

  California’s “Digital Online Erasure” Law

If you are a resident of California under age 18 and a registered user of our services, you may ask us to remove content or information that you have posted to the services by emailing us at info@konamicrossmedia.com with “California Privacy Rights” in the subject line.

• c.

  CCPA

• 1.

  Right to Access: If you are a California resident, you may submit, free of charge, but no more than twice in a 12-month period, a request, subject to our verification of your identity, for the following information:

  • •

    The specific pieces of personal information we have about you;

  • •

    The categories of personal information we collected, sold or disclosed for a business purpose about you within the preceding 12-month period;

  • •

    The categories of sources from which the personal information was collected;

  • •

    The purposes for which the information was collected or sold; and

  • •

    The categories of third parties to whom the information was sold, disclosed for a business purpose, or otherwise shared.

  In some instances, we may decline to honor your request where an exception applies, such as where the disclosure of your personal information would adversely affect the rights and freedoms of another individual.

• 2.

  Right to Deletion: If you are a California resident, you may submit a request, subject to our verification of your identity, for us to delete personal information we have collected from you. In some instances, we may decline to honor your request where an exception applies, such as where we need to retain your personal information in order to complete a transaction with you.

• 3.

  Right to be Free from Discrimination: If you are a California resident, you have the right to be free from unlawful discrimination for exercising your rights under the CCPA.

• 4.

  Exercising Your Rights under the CCPA: To submit a request or for more information about how to exercise your rights, please email us at info@konamicrossmedia.com with “California Privacy Rights” in the subject line, or call us at 212.590.2100. We may request information from you in order to verify your identity, such as your email address or phone number. If you would like an authorized agent to make a request on your behalf, the agent may do so by contacting us at info@konamicrossmedia.com with “California Privacy Rights” in the subject line or by calling us at 212.590.2100. Upon receipt of a request from an agent, we will require the agent’s power of attorney or signed written permission that you have authorized the agent to act on your behalf. We may also require you to verify your own identity. We will respond to your request, or that of your authorized agent, consistent with applicable law.

• 5.

  Personal Information Collected, Sold or Disclosed for a Business Purpose: Under the CCPA we are required to provide you with lists of the categories of personal information we collected, sold or disclosed about certain California residents in the preceding 12 months, by reference to the categories enumerated in the CCPA. The below list includes each of the CCPA’s enumerated categories where we have collected directly from you or from third-party sources, such as public databases, joint marketing partners, social media platforms and other third parties, in the preceding 12 months. We have used the information collected as set forth in our under “Information Use,” above. During the preceding 12 months we have not sold* personal information for purposes of the CCPA. We do not knowingly sell the personal information of individuals under the age of 16. If you have any questions, please contact us using the contact information provided above in section 4.

• Categories of Personal Information Collected:

• •

  Identifiers (Examples: name, alias, postal address, email address, unique personal identifiers [device ID, IP address, etc]);

• •

  Personal Information described in the California safeguards law (Examples: name, signature, postal address, telephone number,;

• •

  Characteristics of protected classifications under California or Federal law (Examples: age);

• •

  Internet or other electronic network activity information (Examples: browsing or search history, interaction with an online service, etc.)**; and

• •

  Geolocation data**.

• *

  The CCPA defines the terms “sell,” “selling” “sale,” and “sold” to include selling, renting, releasing, disclosing, disseminating, making available, transferring, or otherwise communicating a California resident’s personal information for monetary or other valuable consideration. The definition contains certain exceptions, which have been taken into account.

• **

  These items are occasionally disclosed to our service providers or KCM affiliates for our business purposes.

V. Nevada Residents as Covered by Nevada Privacy Law

KCM NY does not sell Covered Information as defined under Nevada law. If you would like to inquire regarding the sale of your Covered Information, as defined under Nevada law, please email us at info@konamicrossmedia.com with “Nevada Privacy Rights” in the subject line.

VI. European Residents Privacy Rights

If you are a data subject in Europe you have certain rights under data protection laws in relation to your data, including the right:

• 1.

  to access, correct, or request erasure any personal data we have collected about you through our website;

• 2.

  to data portability and the right to restrict or object to our processing of personal data we have collected about you through our website;

• 3.

  to ask us not to process your personal data; and

• 4.

  to request restrictions on the processing of your personal data.

We can only process requests from a user whose identity has been identified. To verify your identity, please provide your email address or URL when you make a request. For more information about how to get access to your personal data and for exercising your rights, please contact us via the methods provided in section 18 below. To view additional information about behavioral advertising and manage your preferences, you can do so by visiting: http://www.youronlinechoices.eu/.

The data controller for personal information that you provide or is collected by us is Konami Cross Media NY, Inc., 53 West 23rd Street, 11th Floor, New York, New York 10010.

To make an inquiry pursuant to this section please send an email to info@konamicrossmedia.com or send a written request to EU Privacy Coordinator, Konami Cross Media NY, Inc., 53 West 23rd Street, 11th Floor New York, New York 10010 or call 212.590.2100.

VII. Children

We do not knowingly collect personal information from children under the age of thirteen.

VIII. Changes to this Policy

From time to time, we may make changes to this Policy. These changes will take effect when published on this website, and your use of our website following these changes means that you accept the revised Policy.

November 12, 2020