Please see https://legal.konami.com/kde/kidsprivacy/en/ for the privacy page for children.
Privacy Notice [Games]
Konami Digital Entertainment Co., Ltd. (“KONAMI,” “we”, or “us”) handles your personal data (i.e., any information relating to you as an identifiable individual) when you play KONAMI’s games (“Games”) in accordance with applicable laws and regulations, guidelines, etc., as follows.
In the event that the laws and regulations of countries and regions set forth in the Exhibits apply, the respective relevant Exhibits shall apply in conjunction with this privacy notice (this “Privacy Notice”). Furthermore, if there is a conflict between this Privacy Notice and any Exhibit, the rules of the Exhibit shall prevail.
KONAMI may change, add to, or delete any part of this Privacy Notice from time to time. The most recent version of this Privacy Notice is available on KONAMI’s website https://legal.konami.com/kde/games/view/en/ , and previous versions of this Privacy Notice are available at https://legal.konami.com/kde/games/archive/view/en/ .
1. KONAMI’s Information
Detailed information about KONAMI (including representative names and addresses) is available at https://www.konami.com/games/corporate/en/ .
2. Collection of Personal Data
KONAMI collects your personal data by legal and fair means.
3. Categories of Personal Data to be Processed
The categories of personal data that KONAMI may collect when you play Games are as follows.
- Device information: OS version, etc.
- Network information: IP address, etc.
- Transaction information: Records of your purchases of Games
-
Usage data: Includes the following:
- Play data: The fact that you installed and played certain Games, and records of your activities in the Games (i.e., saved data of the Games, including items and virtual currencies)
- Logs
- Activity data: Includes data on the presence or absence of consent, participation in events, etc.
- Diagnostic data: Data used for technical evaluations, such as crash data and performance data
- User data: Information about you and your selections that you send to KONAMI through the use of Games (e.g., selected language, country, region)
- Fraud prevention information: Data necessary for KONAMI to prevent unauthorized or fraudulent use of Games
- Identifier(s): User identifier (i.e., user ID) designated by KONAMI and those designated by third parties, including platform IDs, Firebase’s instance IDs, etc.
- Mobile measurement data: Data collected through application analysis tools
4. Purposes of Processing Your Personal Data
KONAMI processes your personal data for the following purposes.
-
To provide you with Games
The following purposes are included:- To properly process purchases of in-game currencies and items (including recovery of granted in-game currencies and items if you cancel purchases).
- To operate Games (including investigating and issuing appropriate responses to users’ misconduct).
-
To provide an environment where you can play Games in a safe, secure, and comfortable manner
The following purposes are included:- To implement security measures to maintain Games in a safe and secure environment
- To implement advance measures to prevent users’ misconduct
- To announce updates, maintenance, etc. to/of Games
- To select applicable information, based on your country of residence and language used
-
To improve the quality of, upgrade, and develop Games
The following purposes are included:- To utilize your feedback to improve the quality of Games·
- To ensure appropriate processing for dispute resolution
- To appropriately process personal information as statistical information
-
To protect children in consideration of public order and morality
The following purposes are included:- To set an upper limit on monthly charges based on the user’s age
-
To protect children and the rights of parents or guardians in accordance with the law
The following purposes are included:- To obtain the consent of parents or guardians based on the user’s age in accordance with the provisions of the law
-
To comply with legal obligations or to respond to legitimate requests from public authorities
The following purposes are included:- To comply with legal obligations imposed on KONAMI and KONAMI’s contractors in the provision of Games
5. Retention Period of Your Personal Data
KONAMI will retain your personal data for as long as necessary for KONAMI to ensure continued delivery of Games. KONAMI may retain your personal data for a maximum of 180 days after KONAMI ceases to process your personal data for the purposes above. However, the foregoing shall not apply in cases where it is necessary to retain your personal data for a longer period of time in order to settle disputes, comply with legal obligations, and/or fulfill contracts between KONAMI and KONAMI’s business partners (including licensors).
6. Counterparty to Share Your Personal Data
KONAMI may share your personal data with other business entities with your consent, or within the scope of the purposes set forth in this Privacy Notice, in each of the situations set forth below. The counterparties with which your personal data may be shared include persons located outside the country in which you are located (i.e., persons located outside Japan, the EEA, or the United Kingdom). KONAMI will lawfully share your personal data with other business entities in accordance with the requirements set forth in any applicable laws and regulations. Please refer to the exhibits attached to this Privacy Notice for the relevant laws and regulations of each country.
a. Konami Group
KONAMI may share your personal data with Konami Group companies within the scope of the items and purposes of use of personal information provided in this Privacy Notice.
A list of all Konami Group companies is available at https://www.konami.com/corporate/en/subsidiaries/ .
b. Service Provider
KONAMI may share your personal data with KONAMI’s contractors (i.e., service providers) in order to provide services to you. A list of KONAMI’s contractors is available at https://legal.konami.com/kde/games/processor-list/ .
c. Other Sharing of Your Personal Data
KONAMI may share your personal data with other companies and organizations pursuant to applicable laws and regulations. This includes cases where KONAMI is ordered by courts, police, governmental agencies, etc., to share your personal data, or cases where other companies acquire KONAMI or a part of KONAMI’s businesses, among others.
7. Technical and Organizational Measures
KONAMI will implement the following technical and organizational measures to protect your personal data.
a. Development of Rules on the Handling of Personal Data
KONAMI has established the Privacy Policy as a basic policy applicable to employees for the protection of personal information and to set forth rules on the handling of personal data and the collection, use, storage, provision, deletion, disposal, etc. of your personal data.
Privacy Policy is available at https://legal.konami.com/en/ .
b. Organizational Security Measures
i. To implement security measures, the Information Security Committee of the KONAMI GROUP CORPORATION is responsible for establishing an information management system, and evaluations, reviews, and improvements of/to security measures are carried out annually.
ii. Personal data is handled pursuant to predetermined operation and management rules.
iii. A personal information management ledger (i.e., record of processing activities) has been developed.
iv. Rules on removing personal data and information systems from KONAMI’s premises have been developed and implemented.
v. When outsourcing work involving the handling of personal data, KONAMI’s security measures continue to apply, and evaluations, reviews, and improvements of/to security measures are carried out annually.
c. Personnel Security Measures
i. Non-disclosure agreements are concluded with all employees at the time they are hired and remain in effect for a specified period of time following termination of employment.
ii. All employees are provided with annual training regarding the appropriate handling of personal information.
d. Physical Security Measures
i. Work involving the handling of personal data is conducted in restricted areas. Information systems that are used to handle personal data are installed in restricted areas.
ii. Access to areas in which personal data is handled is recorded by surveillance cameras at all times, and entrances and exits are kept locked.
iii. The use of external recording media is essentially prohibited in restricted areas.
e. Technical Security Measures
i. Authentication of the identities of the employees who access personal data is required to confirm that access to the data is legitimate.
ii. Access to personal data is controlled via identity authentication, and access authority is granted to employees as necessary based on the nature of their work.
iii. Transmissions of data, including personal data, are encrypted. Both status of use and access to information systems used to handle personal data are also monitored.
iv. Systems used to handle personal data are only accessible using devices managed by KONAMI, and security updates are implemented regularly. Anti-malware and anti-unauthorized software measures are also implemented.
8. Transfers of Your Personal Data to Overseas Business Entities
As described in section 6 above, KONAMI may share your personal data with other business entities located outside the country in which you are located for the purposes set forth in this Privacy Notice. KONAMI protects your personal data in accordance with the applicable laws and regulations.
9. Our Contact Information
You can make general inquiries about KONAMI’s services via the following link: https://www.konami.com/games/inquiry/
If you have any questions about the use of your personal data by KONAMI or the exercise of your rights, inquiries may be made to KONAMI as follows:
- Contact KONAMI: privacynotice@faq.konami.com
-
Contact Data Protection Officer: KONAMI has appointed a Data Protection Officer (DPO) who is responsible for the use of your personal data by Konami Group.
DPO: Masahiko Kimura
You may contact the DPO by e-mail (dpo-team@konami.com).
End
- Exhibit (Japan)
- Exhibit (EEA, UK and Specific Jurisdictions)
- Exhibit (California)
- Exhibit (Brazil)
- Exhibit (Indonesia)
- Exhibit (Singapore)
- Exhibit (Thailand)
- Exhibit (Turkey)
- Exhibit (Korea)
Exhibit (Japan)
The provisions of this Exhibit also apply to customers residing in Japan.
1. Your Right to Make Requests for Disclosure and Other Actions Relating to Personal Information
The procedures for requesting the disclosure, correction, addition, deletion, suspension of use, erasure, etc. of personal data by/from KONAMI (“Request”) are as follows.
(1) Request Form
When submitting a Request in connection with games, please contact us using the inquiry form for games. Please contact us regarding any other type of request using the KONAMI Customer Support Center Page ( https://www.konami.com/games/inquiry/jp/ ).
When you contact us, we first verify the identity of the owner of the data for your Request, and generally respond to you within 30 days following identity verification. In certain cases, we may postpone our response up to a maximum of 90 days.
(2) Methods of Identity Verification (Requests from You)
We verify your identity using the following methods.
-
Mobile Games/Applications
We verify the identity of the user of the game account after receiving an inquiry via the in-game contact window or through the designated inquiry method. -
Video Games
We verify the identity of the user of the game account by the method designated by us after receiving an inquiry through the contact window on the official game website. -
KONAMI ID and KONAMI Style
After receiving inquiries through the KONAMI ID or KONAMI Style contact window, we confirm the registered information, including e-mail address, in order to verify your identity. -
Events and Competitions
We verify your identity using the method designated by us. -
Other
We verify your identity using the method designated by us.
(3) Method of Identity Verification (Requests from Agent)
When making a Request through an agent, please contact us using the KONAMI Customer Support Center Page. You may need to submit the following documents for identity verification for your Request regarding KONAMI ID. With respect to a Request regarding matters other than KONAMI ID, we verify your identity using the method designated by us.
- In the event that a legal guardian (e.g. person with parental authority) submits a Request, it is necessary to provide one copy of a document confirming the person’s status as a legal guardian, such as a copy of the certificate of residence (jyuminhyo), or a certified copy of family register (koseki-tohon or koseki-ziko-shomeisho) (within three months after issuance).
- In the event that an agent (e.g. attorney-at-law) submits a Request, it is necessary to provide one copy of the power of attorney (with your signature and registered seal impression affixed), and one copy of the registered seal certificate.
(4) Matters to be Noted
Documents and data submitted in connection with a Request will not be returned. We will retain the documents and data you submit for the required period.
The foregoing shall also apply when the Request involves deletion of personal information, including after we have deleted the relevant personal information in response to such request.
We will respond to the person making the Request (or their agent, where applicable) by e-mail or telephone.
2. Joint Use in Konami Group
KONAMI may jointly use your personal data with each company in Konami Group within the scope of the items and purposes of use of personal information provided in the Privacy Notice. In such cases, KONAMI GROUP CORPORATION shall be responsible for the management of such joint use. Representative names and addresses are available at https://www.konami.com/corporate/en/data/ .
A list of all Konami Group companies is available at https://www.konami.com/corporate/en/subsidiaries/ .
3. External Transmission of User Information
We may send information from your device to external parties for the purpose of updating products and services, improving quality, measuring use of websites, evaluating advertising effectiveness, etc.
External Transmission Destination List
https://legal.konami.com/games/telecom-jp/ja/ext-trans.html
Exhibit (EEA, UK and Specific Jurisdictions)
The provisions of this Exhibit also apply to customers residing in the following countries or regions:
EEA, UK:
Austria, Belgium, Bulgaria, the Czech Republic, Croatia, Cyprus, Denmark, Estonia, Finland, France, Germany, Greece, Hungary, Iceland, Ireland, Italy, Latvia, Liechtenstein, Lithuania, Luxembourg, Malta, the Netherlands, Norway, Poland, Portugal, Romania, Slovakia, Slovenia, Spain, Sweden and the United Kingdom
Specific Jurisdictions:
Albania, Algeria, Bahrain, Ecuador, Egypt, Ghana, Honduras, Jamaica, Kenya, Mauritius, Morocco, Peru, the Philippines, Saudi Arabia, Serbia, Singapore, Somalia, South Africa, Taiwan and Uzbekistan
1. Legal Basis for Processing Your Personal Data
The legal basis for KONAMI to process your personal data is as follows, and depends on the purpose of use.
| Purpose of Use | Legal basis |
|---|---|
|
To provide you with Games The following purposes are included:
|
Performance of contract |
|
To provide an environment where you can play Games in a safe, secure, and comfortable manner The following purposes are included:
|
Legitimate interests |
|
To improve the quality of, upgrade, and develop Games The following purposes are included:
|
Legitimate interests |
| To ensure appropriate processing for dispute resolution | Legitimate interests |
| To appropriately process personal information as statistical information | Legitimate interests |
|
To protect children in consideration of public order and morality The following purposes are included:
|
Legitimate interests |
|
To protect children and the rights of parents or guardians in accordance with the law The following purposes are included:
|
Legal obligations |
|
To comply with legal obligations or to respond to legitimate requests from public authorities The following purposes are included:
|
Legal obligations |
Performance of contract: This means that in order for KONAMI to fulfill its obligations under a contract established between you and us. KONAMI must process your personal data based on the contract, or take measures at your request before entering into the contract.
Legitimate interests: This means KONAMI’s interests in its business operations to deliver high quality KONAMI services in a manner that is enjoyable and safe for you. When processing your personal data by relying on legitimate interests, KONAMI will consider the potential benefits and risks it may pose to you. KONAMI only will collect and use your personal data for its legitimate interests if KONAMI confirms that there are no unacceptable risks to you, and you retain the right to object to KONAMI’s processing of such personal data. Please contact us for further details.
Legal obligations: This means that KONAMI processes your personal data when KONAMI must comply with legal obligations.
In addition, KONAMI may process your personal data for the purposes of use stated in the following table after obtaining your consent.
| Purpose of Use | Legal basis |
|---|---|
| To provide you with related services that enhance the convenience and entertainment aspects of Games | Consent |
| To provide functions to enhance the convenience and entertainment aspects of services you receive through the use of your location information | Consent |
| To improve, upgrade, develop, and operate products and services of KONAMI | Consent |
|
To distribute digital advertisements, including Personalised ads, based on your data “Personalised Ads” is defined as follows: Advertisements that are optimised for you based on your demographic, psychographic, geographic and behavioural data. |
Consent |
| To display advertisements from others related to the Games | Consent |
| To evaluate the effectiveness of KONAMI’s advertising | Consent |
| To inform you about products and services of KONAMI | Consent |
| For you to respond to questionnaires regarding products and services of KONAMI | Consent |
Consent: This means that KONAMI processes your personal data where we have obtained clear, specific, and voluntary consent (or the consent of your parent/guardian, if you are of an age where parental consent is required under applicable law). When KONAMI’s processing of your personal data is performed with your consent, KONAMI will provide sufficient information for you to determine whether your personal data may be processed and provide your consent. KONAMI will also keep records of your consent. You are not obligated to consent to KONAMI’s processing of your personal data and you may withdraw your consent at a later date by using the method explained to you when we first obtained your consent.
2. Automated Decision-Making
KONAMI does not process personal data using automated decision-making.
3. Your Rights Under Data Protection Laws
You have the following legal rights with respect to your personal data:
- Rights of Access: You have the right to request that KONAMI provide you with copies of your personal data at any time. As there are some restrictions on this right, KONAMI may not be able to provide you with all the information you request.
- Rights to Rectification: You have the right to request that KONAMI correct your personal data at any time if it is found to be inaccurate, or to supplement such data if it is incomplete.
- Rights to Erasure: Under certain circumstances, you may request that KONAMI delete your personal data.
- Rights to Restriction of Processing: Under certain circumstances, you may request that KONAMI restrict its use of your personal data.
- Rights to Data Portability: Under certain circumstances, you may request that KONAMI transfer your personal data to another organization or to you in a form commonly used for storage of and access to such data. This right applies only if you provide KONAMI with your personal data and the legal basis for KONAMI’s use of your personal data is either your consent or a contractual agreement.
- Rights to Object: Under certain circumstances, you may object to KONAMI’s use of your personal data. This right applies only if the legal basis for KONAMI’s use of your personal data is a legitimate interest. Upon receiving such objection, KONAMI will cease to use your personal data. However, KONAMI may continue to use such data if it has a legitimate reason and if its continued use will not cause any unacceptable risks to you. KONAMI will cease to use the data if your objection relates to direct marketing.
- Withdrawal of Consent: If you have consented to KONAMI’s use of your personal data, you retain the right to reconsider and withdraw your consent at any time.
- Rights to Reject Automated Decision-Making, Including Profiling: Data protection laws in some countries and other laws may grant you the right to reject the use of your personal data if it is likely that any decisions relating to you based on profiling or other forms of automated processing may affect you negatively (either legally or in any other material sense). As stated above, KONAMI does not process personal data using automated decision-making.
The exercise of the rights outlined above shall be conducted in the following manner.
- Time required for response: KONAMI aims to respond to personal data requests within 30 days. In some cases (e.g., if your request is complicated, or if you make many requests), it may take longer than 30 days. Should KONAMI be unable to respond to your request within 30 days, KONAMI will provide you with a reasonable explanation for its inability to respond.
- Additional information about you: KONAMI may ask you to provide additional information to verify your identity. This is a security measure to ensure that personal data is provided appropriately and to the correct individual. In addition, KONAMI may contact you to clarify your request.
- Fees: Generally, KONAMI does not charge a fee for accessing your personal data or for exercising any other rights. However, if KONAMI determines that your request is unreasonable (for example, if you submit an excessive number of requests or request a large volume of information), KONAMI may demand reasonable fees. In these situations, KONAMI may not be able to comply with your requests.
4. How to File a Complaint
If you believe that KONAMI has failed to properly manage or has misused your personal data, please contact KONAMI, and KONAMI will provide its best efforts to resolve the issue. In addition, you may file a complaint with the relevant governmental authorities in your country (i.e., governmental regulatory bodies responsible for data protection) regarding KONAMI’s use of your personal data.
5. Cross-border Transfers of Personal Data
Your personal data collected by KONAMI may be stored at secure data centers operated by service providers located outside your country or region of residence.
The adequacy of the Personal Information Protection Act of Japan has been certified by the EEA and the United Kingdom as providing the same level of protection as data protection laws of the EEA and the United Kingdom. In addition, if KONAMI transfers your personal data to service providers in countries other than Japan, KONAMI will comply with the requirements imposed by the EEA and U.K., implement appropriate safeguards, and take measures to ensure that the same level of protection for your personal data is maintained.
6. Contact Addresses of KONAMI’s Representatives in the EEA or the United Kingdom
If you are in the EEA or in the United Kingdom and would prefer to contact our local representative, you can do so via the following e-mail address.
- Representative in the EEA: French Branch Office of Konami Digital Entertainment B.V. by e-mail ( rep-gdpr@konami.info ).
- Representative in the U.K.: UK Branch Office of Konami Digital Entertainment B.V. by e-mail ( rep-gdpr@konami.info ).
Exhibit (California)
In addition to the Privacy Notice, this Exhibit applies to the handling of your Personal Information (meaning information that identifies, relates to, describes, references, is capable of being associated with, or could reasonably be linked to, directly or indirectly, a particular consumer or household; the same shall apply hereinafter in this Exhibit) if you reside in the State of California, in accordance with the articles of the California Consumer Privacy Act (meaning the California Consumer Privacy Act of 2018 as amended by the California Privacy Rights Act of 2020; the “CCPA”). In the event of any inconsistency or conflict between the clauses of the Privacy Notice and the clauses of this Exhibit, the clauses of Exhibit shall prevail.
The terms defined under the CCPA are used in the sections below. In particular, “sell,” “selling,” “sale,” or “sold” means that KONAMI sells, rents, releases, discloses, disseminates, makes available, transfers, or otherwise communicates orally, in writing, or by electronic or other means, your Personal Information to a third party for monetary or other valuable consideration. In addition, “share,” “shared,” or “sharing” means sharing, renting, releasing, disclosing, disseminating, making available, transferring, or otherwise communicating orally, in writing, or by electronic or other means, your Personal Information to a third party for cross-context behavioral targeting advertising, whether for monetary or other valuable consideration. Under the CCPA, if KONAMI has entered into an appropriate contract with a third party regarding the handling of Personal Information, any actions covered by that contract are not considered to be “sell,” “selling,” “sale,” or “sold.”
1. Collection and Use of Personal Information
The categories of your Personal Information that KONAMI has collected in the past twelve (12) months or may collect in the future are outlined in the “Categories of Personal Information Disclosed” and “Examples of Personal Information” columns in 2.(2) (Disclosure of Personal Information for Business Purposes) of this Exhibit.
KONAMI will use the Personal Information outlined above for the purposes stated in 4. (Purposes of Processing Your Personal Data) of the Privacy Notice. All of this Personal Information will be collected directly from you.
2. Sale, Sharing, and Disclosure of Personal Information
The table below lists the categories of your Personal Information that KONAMI has sold, shared, or disclosed to third parties for business purposes in the past twelve (12) months, as well as the categories of third parties to whom it was sold, shared, or disclosed in the past twelve (12) months. KONAMI may sell, share or disclose your Personal Information to third parties for the purposes outlined in 4. (Purposes of Processing Your Personal Data) of the Privacy Notice.
| Categories of Personal Information Sold, Shared or Disclosed | Examples of Personal Information | Categories of Third Parties to whom Personal Information was Sold, Shared or Disclosed in the Past Twelve (12) Months |
|---|---|---|
| Identifiers (such as names, codes, or other details used to uniquely identify an individual) | User identifiers designated by KONAMI (User ID) and identifiers designated by third parties (platform IDs, Firebase’s instance IDs, etc.). | KONAMI Group companies and service providers (including those offering customer service-related systems, development and system operation services, customer support services, and cloud services), advertising platform and advertising network |
| Additional data covered by the California Customer Records Act (any Personal Information described in subdivision (e) of Section 1798.80) |
|
KONAMI Group companies and service providers (including those offering customer service-related systems, development and system operation services, customer support services, and cloud services), advertising platform and advertising network |
| Commercial information | Transaction information (Records of your purchases in Games, etc.) | KONAMI Group companies and service providers (including those offering customer service-related systems, development and system operation services, customer support services, and cloud services), advertising platform and advertising network |
3. Requests Regarding Handling of Personal Information
You have the following rights with respect to your Personal Information:
(1) Right to Access
You have the right to request that KONAMI disclose the following information about the Personal Information that KONAMI has acquired, used or disclosed in the past twelve (12) months from the time of your request, up to twice within a 12-month period (“right to access”).
the categories of your Personal Information that KONAMI has acquired;
the sources from which such Personal Information was acquired;
KONAMI’s business or commercial purpose(s) for acquiring Personal Information;
the categories of third parties to whom KONAMI has disclosed Personal Information;
the categories of Personal Information disclosed to each third party; and
specific items of your Personal Information that KONAMI has acquired.
(2) Right to Deletion
You have the right to request that KONAMI delete certain Personal Information that KONAMI has acquired from you (“right to deletion”).
(3) Right to Correction
You have the right to request that KONAMI correct inaccurate Personal Information held by KONAMI (“right to correction”).
(4) How to Exercise the Right to Access, Right to Deletion, or Right to Correction
When exercising the right to access, right to deletion, or right to correction mentioned above, please contact KONAMI using the contact information provided below. Upon receiving a request, KONAMI will verify the identity of the requester in advance as follows:
A. Contact Information
Toll-free number : 1-866-444-6528
Email address : privacy-ccpa@faq.konami.com
Web form : https://www.konami.com/games/inquiry/
B. Identity Verification Procedures
(i) Requests from You
When KONAMI receives a request from you to exercise your right to access, right to deletion, or right to correction, KONAMI will ask you to provide sufficient information, such as your name and email address, to verify your identity. This information will be compared with the details KONAMI already holds to confirm your identity.
(ii) Requests from Your Agent
In addition to the procedures described in (i), KONAMI will ask your agent to provide a certificate with your signature confirming that the agent is authorized to exercise your rights on your behalf.
KONAMI may also contact you directly to verify that you have granted the agent the authority to exercise your rights to access, right to deletion, or right to correction of your information.
(5) Additional Information
You have the right to request that KONAMI no longer sell or share your Personal Information. To exercise that right, please click the following Do Not Sell or Share My Personal Information( https://legal.konami.com/kde/do-not-sell-or-share-my-personal-information/ ).
KONAMI will respond to opt-out preference signals sent through Global Privacy Control and treat them as valid requests under the right to opt-out of sales or sharing. For more information about how to use global preference signals, please see Global Privacy Control ( https://legal.konami.com/kde/global-privacy-control/ ).
KONAMI will not discriminate against you for exercising any of your rights under the CCPA.
As permitted by applicable laws, KONAMI may charge a reasonable fee to process your request.
4. Other privacy rights in the state of California
(1) California Online Privacy Protection Act (CalOPPA)
KONAMI does not take measures to respond to “Do Not Track” signals. However, KONAMI and third parties may use tracking technologies to collect Personal Information about your online activities when you visit KONAMI’s website or use KONAMI’s online services.
(2) Shine the Light Law
You have the right to request provision of a list of the categories of Personal Information that KONAMI has disclosed to third parties for direct marketing purposes in the preceding calendar year, and the names and addresses of those third parties free of charge. To exercise this right, please contact us using the contact information provided in 3.(4)A of this Exhibit.
5. Contact Points for Inquiries
If you have any questions or concerns regarding this Exhibit or KONAMI’s privacy practices, please contact KONAMI using the contact information provided in 3.(4)A of this Exhibit.
Exhibit (Brazil)
The provisions of this Exhibit also apply to you if you are residing in Brazil.
1. Application to Brazil
This Exhibit supplements the Privacy Notice to the extent that the Brazilian General Data Protection Law (the “LGPD”) applies in relation to KONAMI’s processing of your personal data. In case of any inconsistencies between this Exhibit and the Privacy Notice, the provisions that impose stricter obligations on KONAMI shall prevail, in accordance with the Privacy Notice. KONAMI conducts its business in compliance with the LGPD and has implemented various measures to ensure that all personal data that KONAMI processes remains safe and secure.
2. Legal Basis for Processing Your Personal Data
The legal basis for KONAMI to process your personal data is as follows, depending on the purpose of use.
| Purpose of Use | Legal basis |
|---|---|
|
To provide you with Games The following purposes are included:
|
Performance of contract |
|
To provide an environment where you can play Games in a safe, secure, and comfortable manner The following purposes are included:
|
Legitimate interests |
|
To improve the quality of, upgrade, and develop Games The following purposes are included:
|
Legitimate interests |
| To ensure appropriate processing for dispute resolution | Exercise of rights in judicial, administrative, or arbitration procedures |
| To appropriately process personal information as statistical information | Legitimate interests |
|
To protect children in consideration of public order and morality The following purposes are included:
|
Legitimate interests |
|
To protect children and the rights of parents or guardians in accordance with the law The following purposes are included:
|
Legal obligations |
|
To comply with legal obligations or to respond to legitimate requests from public authorities The following purposes are included:
|
Legal obligations |
Performance of contract: This means that in order for KONAMI to fulfill its obligations under a contract established between you and us. KONAMI must process your personal data based on the contract, or take measures at your request before entering into the contract.
Legitimate interests: This means KONAMI’s interests in its business operations to deliver high quality KONAMI services in a manner that is enjoyable and safe for you. When processing your personal data by relying on legitimate interests, KONAMI will consider the potential benefits and risks it may pose to you. KONAMI only will collect and use your personal data for its legitimate interests if KONAMI confirms that there are no unacceptable risks to you, and you retain the right to object to KONAMI’s processing of such personal data. Please contact us for further details.
Legal obligations: This means that KONAMI processes your personal data when KONAMI must comply with legal obligations.
Exercise of rights in judicial, administrative, or arbitration procedures: This means that KONAMI processes your personal data when exercising its rights in judicial, administrative, or arbitration procedures.
In addition, KONAMI may process your personal data for the purposes of use stated in the following table after obtaining your consent.
| Purpose of Use | Legal basis |
|---|---|
| To provide you with related services that enhance the convenience and entertainment aspects of Games | Consent |
| To provide functions to enhance the convenience and entertainment aspects of services you receive through the use of your location information | Consent |
| To improve, upgrade, develop, and operate products and services of KONAMI | Consent |
|
To distribute digital advertisements, including Personalised ads, based on your data “Personalised ads” is defined as follows: Advertisements that are optimised for you based on your demographic, psychographic, geographic and behavioural data. |
Consent |
| To display advertisements from others related to the Games | Consent |
| To evaluate the effectiveness of KONAMI’s advertising | Consent |
| To inform you about products and services of KONAMI | Consent |
| For you to respond to questionnaires regarding products and services of KONAMI | Consent |
Consent: This means that KONAMI processes your personal data where we have obtained clear, specific, and voluntary consent (or the consent of your parent/guardian, if you are of an age where parental consent is required under applicable law). When KONAMI’s processing of your personal data is performed with your consent, KONAMI will provide sufficient information for you to determine whether your personal data may be processed and provide your consent. KONAMI will also keep records of your consent. You are not obligated to consent to KONAMI’s processing of your personal data and you may withdraw your consent at a later date by using the method explained to you when we first obtained your consent.
3. Your Rights Under the LGPD
You have the legal rights described below with respect to your personal data:
- Confirmation of data processing: You have the right to ask whether KONAMI is processing your personal data, and they must confirm this.
- Access your data: You can request a report from KONAMI detailing the personal data they have collected and process about you.
- Rectify incomplete, inaccurate or outdated data: If your personal data is incomplete, inaccurate, or outdated, you can request that KONAMI correct or update the information. KONAMI may ask you to provide proof to support your request.
- Request the anonymization, blocking, or erasure of data deemed unnecessary, excessive, or processed in breach of the LGPD: If you believe KONAMI is processing your data unnecessarily, excessively, or in violation of the LGPD, you can request that the data be anonymized, blocked, or erased.
- Request portability of your data to another service or product supplier, in accordance with the regulations to be issued by the Brazilian Data Protection Authority (“ANPD”), while respecting trade and industrial secrets: As the owner of your own personal data, you have the right to request its transfer to another service or product supplier, provided that such transfer complies with ANPD regulations and safeguards trade and industrial secrets.
- Request deletion of data processed based on your consent, except in cases where retention is prescribed by law: If KONAMI is processing your data based on your consent, you may request that this data be deleted. However, the LGPD allows data retention for legal or regulatory obligations, studies conducted by research bodies (with anonymization if possible), transfer to third parties, or exclusive use by the controller if the data is anonymized.
- Obtain information about the entities with whom KONAMI shares your data: You can request information on the entities with whom KONAMI shares your data.
- Obtain information about the possibility of refusing consent and the respective consequences: If your personal data is processed based on your consent, you are entitled to be informed of your right to refuse consent and the consequences of doing so.
- Withdraw your consent to the processing of your data: If your data is processed based on your consent, you can withdraw this consent. Processing carried out based on previously given consent remains valid as long as no revocation request is made.
- Object to processing that violates the LGPD: If you believe KONAMI is processing your data in violation of the LGPD, you can object to such processing. The request will be reviewed, and if KONAMI agrees, the processing will stop.
- Request the revision of decisions taken solely based on the automated processing of your data: If any decisions are made about you solely through automated processing of your data, you can request a review of these decisions.
- File a petition regarding your data with the Brazilian Data Protection Authority: If necessary, you can file a petition regarding how KONAMI handles your personal data with the ANPD.
Before responding to a request to exercise any of the above rights, KONAMI may request information to verify your identity.
In Brazil, the exercise of any of the rights listed above will always be at no cost to you.
4. Cross-border Transfer of Personal Data
KONAMI operates globally, which means your personal data may be transferred to countries outside Brazil. We will ensure that these transfers will be made in compliance with the Privacy Notice and applicable laws. For more information, please contact us using the details provided in 9. of the Privacy Notice.
Exhibit (Indonesia)
In addition to the Privacy Notice, the provisions of this Exhibit also apply to you if you are residing in Indonesia and if you are an Indonesian national, regardless of your location.
1. Application to Indonesia
This Exhibit supplements the Privacy Notice to the extent that the Law No. 11 of 2008 on Electronic Information and Transaction and Law No. 27 of 2022 on Personal Data Protection, as well as their amendments and implementing and related regulations (“PDP Regulations”), apply in relation to KONAMI’s processing of your personal data. In case of any inconsistencies between this Exhibit and the Privacy Notice, the provisions that impose stricter obligations on KONAMI shall prevail, in accordance with the Privacy Notice. KONAMI conducts its business in compliance with the PDP Regulations and has implemented various measures to ensure that all personal data that KONAMI processes remains safe and secure.
2. Definitions
For the purposes of the Privacy Notice including this Exhibit, references to “process/processing” or “processing” include references to them under the PDP Regulations, as follows:
“Process/processing” or “processing” means any activity or operation that is carried out in respect of personal data, such as acquisition and collection, filtering and analysis, retention, fixes and updates, display, announcement, transfer, dissemination, or disclosure; and/or deletion or destruction of the personal data.
3. Legal justifications for the Processing of Personal Data and Processing Period of the Personal Data
Data processing conducted by KONAMI in relation to your personal data is based on your explicit valid consent for the purposes as indicated in 4. of the Privacy Notice and other valid legal grounds in compliance with the prevailing regulations, including the PDP Regulations, as follows.
| Purpose of Use | Legal basis |
|---|---|
|
To provide you with Games The following purposes are included:
|
Performance of contract |
|
To provide an environment where you can play Games in a safe, secure, and comfortable manner The following purposes are included:
|
Legitimate interests |
|
To improve the quality of, upgrade, and develop Games The following purposes are included:
|
Legitimate interests |
| To ensure appropriate processing for dispute resolution | Legitimate interests |
| To appropriately process personal information as statistical information | Legitimate interests |
|
To protect children in consideration of public order and morality The following purposes are included:
|
Legitimate interests |
|
To protect children and the rights of parents or guardians in accordance with the law The following purposes are included:
|
Legal obligations |
|
To comply with legal obligations or to respond to legitimate requests from public authorities The following purposes are included:
|
Legal obligations |
In addition, KONAMI may process your personal data for the purposes of use stated in the following table after obtaining your consent.
| Purpose of Use | Legal basis |
|---|---|
| To provide you with related services that enhance the convenience and entertainment aspects of Games | Consent |
| To provide functions to enhance the convenience and entertainment aspects of services you receive through the use of your location information | Consent |
| To improve, upgrade, develop, and operate products and services of KONAMI | Consent |
|
To distribute digital advertisements, including Personalised ads, based on your data “Personalised ads” is defined as follows: Advertisements that are optimised for you based on your demographic, psychographic, geographic and behavioural data. |
Consent |
| To display advertisements from others related to the Games | Consent |
| To evaluate the effectiveness of KONAMI’s advertising | Consent |
| To inform you about products and services of KONAMI | Consent |
| For you to respond to questionnaires regarding products and services of KONAMI | Consent |
Consent: This means that KONAMI processes your personal data where we have obtained clear, specific, and voluntary consent (or the consent of your parent/guardian, if you are of an age where parental consent is required under applicable law). When KONAMI’s processing of your personal data is performed with your consent, KONAMI will provide sufficient information for you to determine whether your personal data may be processed and provide your consent. KONAMI will also keep records of your consent. You are not obligated to consent to KONAMI’s processing of your personal data and you may withdraw your consent at a later date by using the method explained to you when we first obtained your consent.
KONAMI will process your personal data for the period necessary to fulfil the purposes for which it has been collected, in accordance with the PDP regulations. Once the purpose has been achieved, the personal data will be destructed or retained as necessary for the period specified in 5. of the Privacy Notice, or for the period permitted under the PDP Regulations.
In any event, KONAMI has implemented various measures to ensure that any of your personal data remains safe and secure, and KONAMI will only process your personal data based on the valid legal grounds under the PDP Regulations.
4. Your Rights
You may contact KONAMI’s Data Protection Officer through the contact information as stated in 9. of the Privacy Notice to inquire about your further rights under the PDP Regulations and to exercise your rights subject to the PDP Regulations. KONAMI will respond to your request as soon as reasonably possible within the time specified by the PDP Regulations.
5. Destruction of Your Personal Data
KONAMI will destroy your personal data without delay as required by the PDP Regulations, including when:
a. the retention period has expired and is described as being destroyed based on the archive retention schedule; and/or
b. you request KONAMI to destroy your personal data.
The procedures and methods for the destruction of your personal data shall follow the provisions under the PDP Regulations.
Exhibit (Singapore)
The provisions of this Exhibit also apply to you if you are residing in Singapore.
1. Application to Singapore
This Exhibit supplements the Privacy Notice to the extent that the Personal Data Protection Act 2012 of Singapore (the “PDPA”) applies in relation to KONAMI’s collection, use and/or disclosure of your personal data. In case of any inconsistencies between this Exhibit and the Privacy Notice, the provisions that impose stricter obligations on KONAMI shall prevail, in accordance with the Privacy Notice. KONAMI conducts its business in compliance with the PDPA and has implemented various measures to ensure that all personal data that KONAMI collects, use and/or disclose remains safe and secure.
2. Collection of Personal Data
“Personal data” refers to any data, whether true or not, about an individual (including, but not limited to, you) who can be identified from that data, or from that data and other information to which KONAMI has or is likely to have access, including data in KONAMI’s records as may be updated from time to time. Personal data which KONAMI may collect includes, without limitation, your personal data falling within the categories set out under 3. of the Privacy Notice.
KONAMI generally collects your personal data only for the purposes and on the legal bases set out under 1. of the Exhibit (EEA, UK and Specific Jurisdictions), to the extent permitted by or in compliance with the PDPA or other applicable laws.
3. Accuracy, Access, and other Rights to your Personal Data
You may exercise your rights in relation to access, correction, withdrawal of consent and other rights under the PDPA via the contact point set out in 9. of the Privacy Notice. KONAMI will handle your request in accordance with the procedure explained in 3. of the Exhibit (EEA, UK and Specific Jurisdictions).
Should KONAMI not be able to respond to your request within thirty (30) days after receiving your request, KONAMI will inform you in writing within thirty (30) days of the time by which KONAMI will be able to respond to your request. If KONAMI is unable to provide you with any personal data which you have requested for, KONAMI shall generally inform you of the reasons why KONAMI is unable to do so (except where KONAMI is not required to do so under the PDPA).
4. Governing Law
This Exhibit shall be governed in all respects by the laws of Singapore and the parties hereto submit to the exclusive jurisdiction of the Singapore courts.
Exhibit (Thailand)
The provisions of this Exhibit also apply to you if you are residing in Thailand.
1. Application to Thailand
This Exhibit supplements the Privacy Notice to the extent that the Personal Data Protection Act B.E. 2562 (“PDPA”) applies in relation to KONAMI’s processing of your personal data. In the event of any inconsistencies between this Exhibit and the Privacy Notice, the provisions that impose stricter obligations on KONAMI shall prevail, in accordance with the Privacy Notice. KONAMI conducts its business in compliance with the PDPA and has implemented various measures to ensure that all personal data that KONAMI processes remains safe and secure.
2. Source of Personal Data
KONAMI collects personal data through the following means:
- Personal data provided directly by the data subject, including when you register or apply for attending the KONAMI’s activities or using any services of the KONAMI
- Identifiers assigned directly to you by KONAMI, along with personal data generated by KONAMI and linked to those identifiers.
- Personal data automatically collected through mobile measurement tools and other methods.
3. Legal Basis for Processing Your Personal Data
KONAMI processes your personal data on the legal bases: (i) Performance of contract; (ii) Legal obligation; and (iii) Legitimate interests, as follows:
| Purpose of Use | Legal basis |
|---|---|
|
To provide you with Games The following purposes are included:
|
Performance of contract |
|
To provide an environment where you can play Games in a safe, secure, and comfortable manner The following purposes are included:
|
Legitimate interests |
|
To improve the quality of, upgrade, and develop Games The following purposes are included:
|
Legitimate interests |
| To ensure appropriate processing for dispute resolution | Legitimate interests |
| To take measures required by applicable laws in connection with dispute resolution | Legal obligations |
| To appropriately process personal information as statistical information | Legitimate interests |
|
To protect children in consideration of public order and morality The following purposes are included:
|
Legitimate interests |
|
To protect children and the rights of parents or guardians in accordance with the law The following purposes are included:
|
Legal obligations |
|
To comply with legal obligations or to respond to legitimate requests from public authorities The following purposes are included:
|
Legal obligations |
Performance of contract: This means that in order for KONAMI to fulfill its obligations under a contract established between you and us, KONAMI must process your personal data based on the contract, or take measures at your request before entering into the contract.
Legitimate interests: This means KONAMI’s interests in its business operations to deliver high quality KONAMI services in a manner that is enjoyable and safe for you. When processing your personal data by relying on legitimate interests, KONAMI will consider the potential benefits and risks it may pose to you. KONAMI only will collect and use your personal data for its legitimate interests if KONAMI confirms that there are no unacceptable risks to you, and you retain the right to object to KONAMI’s processing of such personal data. Please contact us for further details.
Legal obligations: This means that KONAMI processes your personal data when KONAMI must comply with legal obligations.
In addition, KONAMI may process your personal data for the purposes of use stated in the following table after obtaining your specific express consent.
| Purpose of Use | Legal basis |
|---|---|
| To provide you with related services that enhance the convenience and entertainment aspects of Games | Consent |
| To provide functions to enhance the convenience and entertainment aspects of services you receive through the use of your location information | Consent |
| To improve, upgrade, develop, and operate products and services of KONAMI | Consent |
|
To distribute digital advertisements, including Personalised ads, based on your data “Personalised ads” is defined as follows: Advertisements that are optimised for you based on your demographic, psychographic, geographic and behavioural data. |
Consent |
| To display advertisements from others related to the Games | Consent |
| To evaluate the effectiveness of KONAMI’s advertising | Consent |
| To inform you about products and services of KONAMI | Consent |
| For you to respond to questionnaires regarding products and services of KONAMI | Consent |
Consent: This means that KONAMI processes your personal data where we have obtained clear, specific, and voluntary consent (or the consent of your parent/guardian, if you are of an age where parental consent is required under applicable law). When KONAMI’s processing of your personal data is performed with your consent, KONAMI will provide sufficient information for you to determine whether your personal data may be processed and provide your consent. KONAMI will also keep records of your consent. You are not obligated to consent to KONAMI’s processing of your personal data and you may withdraw your consent at a later date by using the method explained to you when we first obtained your consent.
In certain cases, we may need to process your personal data to fulfill our performance of contract which we have with you or comply with applicable legal and regulatory requirements. Failure to provide the requested personal data may result in our inability to deliver certain services or fulfill our obligations effectively. Rest assured that we only collect and process personal data necessary for these purposes and in accordance with the PDPA.
4. Your Rights Under the PDPA
You have the following legal rights with respect to your personal data:
- Rights of Access: You have the right to request that KONAMI provide you with copies of your personal data at any time. As there are some restrictions on this right, KONAMI may not be able to provide you with all the information you request.
- Rights to Rectification: You have the right to request that KONAMI correct your personal data at any time if it is found to be inaccurate, or to supplement such data if it is incomplete.
- Rights to Erasure: Under certain circumstances, you may request that KONAMI delete your personal data.
- Rights to Restriction of Processing: Under certain circumstances, you may request KONAMI that restrict its use of your personal data.
- Rights to Data Portability: Under certain circumstances, you may request that KONAMI transfer your personal data to another organization or to you in a form commonly used for storage of and access to such data. This right applies only if you provide KONAMI with your personal data and the legal basis for KONAMI’s use of your personal data is either your consent or a contractual agreement.
- Rights to Object: Under certain circumstances, you may object to KONAMI’s use of your personal data. This right applies only if the legal basis for KONAMI’s use of your personal data is a legitimate interest. Upon receiving such objection, KONAMI will cease to use your personal data. However, KONAMI may continue to use such data if it has a legitimate reason and if its continued use will not cause any unacceptable risks to you. KONAMI will cease to use the data if your objection relates to direct marketing.
- Withdrawal of Consent: If you have consented to KONAMI’s use of your personal data, you retain the right to reconsider and withdraw your consent at any time.
The exercise of the rights outlined above shall be conducted in the following manner.
- Time required for response: KONAMI aims to respond to personal data requests within 30 days. In some cases (e.g., if your request is complicated, or if you make many requests), it may take longer than 30 days. In addition, please note that as stated above, there may be exceptions to the legal rights you have under applicable laws, and there are circumstances under which the rights may not apply.
- Additional information about you: KONAMI may require you to provide additional information to verify your identity. This is a security measure to ensure that personal data is provided appropriately and to the correct individual. In addition, KONAMI may contact you to clarify your request.
- Fees: Generally, KONAMI does not charge a fee for accessing your personal data or for exercising any other rights. However, if KONAMI determines that your request is unreasonable (for example, if you submit an excessive number of requests or request a large volume of information), KONAMI may demand reasonable fees. In these situations, KONAMI may not be able to comply with your requests.
5. Supervisory Authority
In case you view that KONAMI fails to comply with any provision of the PDPA, you may file a complaint to the Office of Personal Data Protection Committee (PDPC) at the following contact details:
Email saraban@pdpc.or.th
Telephone +66 2111 8800
6. Personal Data of Minors
In some circumstances, we may process personal data of minors which we obtain from you.
When you provide personal data of minors to us, we require you to be fully eligible to act as parent or guardian, to be aware of the situation, to provide consent to us or to be allowed to provide the information pursuant to applicable laws, and to subsequently notify the person under your legal guardianship of your provision of his or her personal data to us.
If we become aware that we have collected personal data from minors without verification of parental/guardian consent, we take steps to remove that information accordingly.
Exhibit (Turkey)
The provisions of this Exhibit also apply to you if you are residing in Turkey.
1. Application to Turkey
This Exhibit supplements the Privacy Notice to the extent that the Law on the Protection of Personal Data (the “LPPD”) applies in relation to KONAMI’s processing of your personal data. In case of any inconsistencies between this Exhibit and the Privacy Notice, the provisions that impose stricter obligations on KONAMI shall prevail, in accordance with the Privacy Notice. KONAMI conducts its business in compliance with the LPPD and has implemented various measures to ensure that all personal data that KONAMI processes remains safe and secure.
2. Purpose and Legal Basis for Processing Your Personal Data
The collected personal data may be processed for the following purposes and legal basis and within the scope of the personal data processing conditions and purposes specified below in accordance with Articles 5 and 6 of the LPPD.
| Purpose of Use | Legal basis |
|---|---|
|
To provide you with Games The following purposes are included:
|
Performance of contract |
|
To provide an environment where you can play Games in a safe, secure, and comfortable manner The following purposes are included:
|
Legitimate interests |
|
To improve the quality of, upgrade, and develop Games The following purposes are included:
|
Legitimate interests |
| To ensure appropriate processing for dispute resolution | Legitimate interests |
| To appropriately process personal information as statistical information | Legitimate interests |
|
To protect children in consideration of public order and morality The following purposes are included:
|
Legitimate interests |
|
To protect children and the rights of parents or guardians in accordance with the law The following purposes are included:
|
Legal obligations |
|
To comply with legal obligations or to respond to legitimate requests from public authorities The following purposes are included:
|
Legal obligations |
Performance of contract: This means that in order for KONAMI to fulfill its obligations under a contract established between you and us. KONAMI must process your personal data based on the contract, or take measures at your request before entering into the contract.
Legitimate interests: This means KONAMI’s interests in its business operations to deliver high quality KONAMI services in a manner that is enjoyable and safe for you. When processing your personal data by relying on legitimate interests, KONAMI will consider the potential benefits and risks it may pose to you. KONAMI only will collect and use your personal data for its legitimate interests if KONAMI confirms that there are no unacceptable risks to you.
Legal obligations: This means that KONAMI processes your personal data when KONAMI must comply with legal obligations.
In addition, KONAMI may process your personal data for the purposes of use stated in the following table after obtaining your consent.
| Purpose of Use | Legal basis |
|---|---|
| To provide you with related services that enhance the convenience and entertainment aspects of Games | Consent |
| To provide functions to enhance the convenience and entertainment aspects of services you receive through the use of your location information | Consent |
| To improve, upgrade, develop, and operate products and services of KONAMI | Consent |
|
To distribute digital advertisements, including Personalised ads, based on your data “Personalised ads” is defined as follows: Advertisements that are optimised for you based on your demographic, psychographic, geographic and behavioural data. |
Consent |
| To display advertisements from others related to the Games | Consent |
| To evaluate the effectiveness of KONAMI’s advertising | Consent |
| To inform you about products and services of KONAMI | Consent |
| For you to respond to questionnaires regarding products and services of KONAMI | Consent |
Consent: This means that KONAMI processes your personal data where we have obtained clear, specific, and voluntary consent (or the consent of your parent/guardian, if you are of an age where parental consent is required under applicable law). When KONAMI’s processing of your personal data is performed with your consent, KONAMI will provide sufficient information for you to determine whether your personal data may be processed and provide your consent. KONAMI will also keep records of your consent. You are not obligated to consent to KONAMI’s processing of your personal data and you may withdraw your consent at a later date by using the method explained to you when we first obtained your consent.
3. Recipient Parties and Purposes for Transferring Personal Data
Your collected personal data may be transferred for the above-mentioned purposes to:
a. KONAMI Group
With your consent, KONAMI may share your personal data with KONAMI Group companies within the scope of the items and purposes of use of personal information provided in this Privacy Notice.
A list of all KONAMI Group companies are available at https://www.konami.com/corporate/en/subsidiaries/ .
b. Service Provider
For performance of contract and within the scope of legitimate interest or the legal obligations, or with your consent, KONAMI may share your personal data with KONAMI’s contractors (i.e., service providers) in order to provide services to customers. A list of KONAMI’s contractors is available at https://legal.konami.com/kde/games/processor-list/ .
c. Other Sharing of Your Personal Data
Within the scope of legitimate interest or the legal obligations, or with your consent, KONAMI may share your personal data with other companies and organizations pursuant to applicable laws and regulations. This includes cases where KONAMI is ordered by courts, police, governmental agencies, etc., to share your personal data, or cases where other companies acquire KONAMI or a part of KONAMI’s businesses, among others.
d. Cross-Border Data Transfers of Personal Data
If the third parties to whom the data is transferred are located outside of Turkey, KONAMI will transfer your personal data in accordance with the rules to be followed when transferring data abroad as stipulated in Article 9 of the LPPD.
4. Method for the Collection of Personal Data
Your personal data may be collected in the electronic environment through the games you play.
5. Your Rights Under Article 11 of the LPPD
We hereby declare that as personal data subjects, you are entitled to the following rights, set forth under Article 11 of the Law:
- Confirmation of Data Processing: You have the right to be informed as to whether your personal data is being processed and to demand information regarding whether your personal data has been processed.
- Request Information on Purpose of Data Processing: You have the right to be informed of the purpose of the processing of your personal data and whether your personal data is used in compliance with this purpose.
- Request Information on Data Transfer: You have the right to know the third parties (either in Turkey or abroad) to which your personal data is transferred.
- Request Rectification: You have the right to request the rectification of any of your personal data that is incomplete or inaccurate.
- Request Erasure: You have the right to request the erasure or destruction of your personal data under the conditions set forth in Article 7 of the LPPD.
- Request Reporting about Rectification or Erasure: You have the right to request reporting of the actions taken pursuant to requests for rectification or erasure to the third parties to which your personal data has been transferred.
- Objection to Automated Decisions: You have the right to object to an outcome which results from your personal data being processed solely by automated systems.
- Claim for Compensation: You have the right to claim compensation for any damage which results from the unlawful processing of your personal data.
You may send your requests concerning your rights listed above to KONAMI via e-mail and, depending on the nature of your request, KONAMI will act on your request or refuse it with justified grounds and notify you as soon as possible, but no later than 30 days, and in principle free of charge. However, if the process involves additional costs, a fee may be charged according to the tariff set by the Personal Data Protection Board.
Exhibit (Korea)
The provisions of this Exhibit also apply to you if you are residing in Korea.
1. Application to the Republic of Korea
This Exhibit supplements the Privacy Notice to the extent that the Personal Information Protection Act (the “PIPA”) applies in relation to KONAMI’s processing of your personal data. In case of any inconsistencies between this Exhibit and the Privacy Notice, the provisions that impose stricter obligations on KONAMI shall prevail, in accordance with the Privacy Notice. KONAMI conducts its business in compliance with the PIPA and has implemented various measures to ensure that all personal data that KONAMI processes remains safe and secure.
2. Details of Personal Data We Process About You
a. Processing of Personal Data without Your Consent
KONAMI is processing the following personal data without your consent.
| Legal basis | Purpose of collection | Item(s) of personal data to be collected | Retention period |
|---|---|---|---|
| Performance of contract |
To provide you with Games The following purposes are included:
|
|
Period specified in 5. of the Privacy Notice |
| Legitimate interests |
To provide an environment where you can play Games in a safe, secure, and comfortable manner The following purposes are included:
|
|
Period specified in 5. of the Privacy Notice |
| Legitimate interests |
To improve the quality of, upgrade, and develop Games The following purposes are included:
|
|
Period specified in 5. of the Privacy Notice |
| Legitimate interests | To ensure appropriate processing for dispute resolution |
|
Period specified in 5. of the Privacy Notice |
| Legitimate interests | To appropriately process personal information as statistical information |
|
Period specified in 5. of the Privacy Notice |
| Legitimate interests |
To protect children in consideration of public order and morality The following purposes are included:
|
|
Period specified in 5. of the Privacy Notice |
| Legal obligations |
To protect children and the rights of parents or guardians in accordance with the law The following purposes are included:
|
|
Period specified in 5. of the Privacy Notice |
| Legal obligations |
To comply with legal obligations or to respond to legitimate requests from public authorities The following purposes are included:
|
|
Period specified in 5. of the Privacy Notice |
Performance of contract: This means that in order for KONAMI to fulfill its obligations under a contract established between you and KONAMI. KONAMI must process your personal data based on the contract, or take measures at your request before entering into the contract.
Legitimate interests: This means KONAMI’s interests in its business operations to deliver high quality KONAMI services in a manner that is enjoyable and safe for you. When processing your personal data by relying on legitimate interests, KONAMI will consider the potential benefits and risks it may pose to you. KONAMI only will collect and use your personal data for its legitimate interests if KONAMI confirms that there are no unacceptable risks to you, and you retain the right to object to KONAMI’s processing of such personal data. Please contact KONAMI for further details.
Legal obligations: This means that KONAMI processes your personal data when KONAMI must comply with legal obligations.
b. Processing of Personal Data under Your Consent
KONAMI is processing the following personal data under your consent in accordance with Article 15(1)1 of the PIPA.
| Purpose of collection | Item(s) of personal data to be collected | Retention period |
|---|---|---|
| To provide you with related services that enhance the convenience and entertainment aspects of Games |
|
Period specified in 5. of the Privacy Notice |
| To improve, upgrade, develop, and operate products and services of KONAMI |
|
Period specified in 5. of the Privacy Notice |
|
To distribute digital advertisements, including Personalised ads, based on your data “Personalised ads” is defined as follows: Advertisements that are optimised for you based on your demographic, psychographic, geographic and behavioural data. |
|
Period specified in 5. of the Privacy Notice |
| To display advertisements from others related to the Games |
|
Period specified in 5. of the Privacy Notice |
| To evaluate the effectiveness of KONAMI’s advertising |
|
Period specified in 5. of the Privacy Notice |
| To inform you about products and services of KONAMI |
|
Period specified in 5. of the Privacy Notice |
| For you to respond to questionnaires regarding products and services of KONAMI |
|
Period specified in 5. of the Privacy Notice |
3. Transfer of Personal Data
(a) We process your personal data strictly within the scope specified for the processing purpose. Personal data is transferred to third parties only in cases that fall under Articles 17 and 18 of the PIPA, such as with the consent of the data subject or in accordance with specific legal provisions. In all other circumstances, we do not provide personal data to third parties.
(b) To ensure the smooth provision of services, we obtain your consent in accordance with Article 17(1) of the PIPA and provide personal data only to the extent necessary and minimal. If KONAMI provides your personal data to any party other than entrustees, KONAMI will provide you with the information and the applicable legal grounds for processing required under the PIPA.
(c) We may provide personal data to relevant authorities without your consent in accordance with the relevant laws in Korea. If KONAMI provides your personal data to relevant authorities, KONAMI will provide you with the information and the applicable legal grounds for processing required under the PIPA.
4. Entrustment of Personal Data Processing
(a) We entrust personal data processing tasks to third parties to ensure smooth operations related to personal data management under Article 26 of the PIPA. Please see the list corresponding to the game you play, available at https://legal.konami.com/kde/games/processor-list/ko/ .
(b) If there are any changes to the content of the entrusted tasks or the entrustee, such changes will be disclosed promptly through the Privacy Notice or this Exhibit.
(c) Information regarding the entrustment of personal data processing tasks to entities abroad is described in 5. of this Exhibit.
5. Cross-Border Transfer of Personal Data
We may transfer your personal data in accordance with 6. and 8. of the Privacy Notice as described below. If you do not want to transfer your personal data overseas, you can refuse or request withdrawal by contacting KONAMI, in which case KONAMI may be unable to provide you with its services.
(a) Provision of Your Personal Data to Foreign Third Parties: KONAMI will provide your personal data to third parties pursuant to your consent or other applicable legal bases under Article 28-8(1) of the PIPA. If KONAMI provides your personal data to any foreign party other than entrustees, KONAMI will provide you with the information and the applicable legal grounds for processing required under the PIPA.
(b) Entrustment of the Processing of Your Personal Data to Foreign Entrustees: KONAMI will entrust the processing of your personal data to foreign entrustees pursuant to Article 28-8(1)(iii) of the PIPA. Please see the list corresponding to the game you play, available at https://legal.konami.com/kde/games/processor-list/ko/ .
6. Overseas Collection of Personal Information
KONAMI collects and processes your personal information from Japan to enable you to use products and services of KONAMI.
7. Destruction of Your Personal Data
KONAMI will destroy your personal data without delay when it is no longer required, e.g., when the retention period of your personal data has expired or the purpose for which it was processed has been achieved. The procedures and methods for the destruction of your personal data are as follows:
(a) Destruction Procedures: KONAMI selects the relevant part of your personal data to be destroyed and proceeds with the destruction with the approval of the person responsible for personal data protection in the department processing personal data.
(b) Destruction Methods: KONAMI destroys your personal data that is recorded and stored in the form of electronic files by using a method that ensures that your personal data cannot be reproduced, and your personal data that is recorded and stored in the form of paper documents is dissolved.
8. Rights and Obligations of You and Legal Representative and Methods of Exercise
(a) You may exercise, at any time, your rights under the PIPA to access, transmit, correct, or delete your personal information, suspend the processing of your personal information, or withdraw your consent. If you are the legal representative of a child under the age of 14, you may exercise such rights on behalf of such child.
(b) Your rights may be exercised through email, inquiry form, or telephone in accordance with Article 41(1) of the Enforcement Decree of the PIPA. KONAMI will take necessary measures without delay.
(c) Rights may be exercised through an agent, such as a legal representative or an individual with a power of attorney. In such cases, a power of attorney in the form provided under Form 11 of the “Guidelines on Personal Information Processing” (available at https://www.law.go.kr/conAdmrulByLsPop.do?&lsiSeq=269291&joNo=0041 ) must be submitted.
(d) Your right to request access to or suspension of the processing of personal data may be restricted under Article 35(4), and Article 37(2) of the PIPA.
(e) If the collection of specific personal data is explicitly required by other laws, you may not be able to request its deletion.
(f) KONAMI will verify that the person exercising the rights is you or your authorized agent.
(g) Rights can be exercised by contacting KONAMI. KONAMI strives to process such requests promptly.
9. Department Responsible for Personal Data Protection
In order to protect your personal data and handle complaints regarding your personal data, KONAMI has established the following personal data protection department:
- Name: KONAMI Customer Support Center
- Contact Details: privacynotice@faq.konami.com
10. Korea Domestic Representative
You may contact our Korea domestic representative to make a complaint about KONAMI’s processing of your personal data. The contact information of our Korea domestic representative is as follows:
- Company: General Agent Co., Ltd.
- Contact Person: Eun Mi Kim
- Email: KONAMI@generalagent.co.kr
- Telephone: 02-737-8110
- Address: Suite 1216, Platinum Building, 28 Saemunan-ro 5ga-gil, Jongno-gu, Seoul, Republic of Korea