This general privacy notice is issued by KONAMI DIGITAL ENTERTAINMENT B.V. ("Konami Europe", “we”, “us” or “our”), a company incorporated in the Netherlands which has its business headquarters at 14-16 Sheet Street, Windsor, SL4 1BG, United Kingdom (our “UK Headquarters”) and has branches in the European Economic Area (“EEA”) in France, Germany and Spain (together, our “EU Branches”).
We may collect and process your personal data through the regular course of our business, such as when you use or contact us through our websites, when we respond to enquiries from you, when we enter into a contract with you or the organisation which you represent, or when you otherwise contact us. In this privacy notice, such general business activities are referred to as “General Business Activities”.
The way in which we collect, use and protect your personal data in connection with General Business Activities is very important to us to ensure that we meet your expectations and our legal requirements under Data Protection Laws (as defined below). How we do this is explained in more detail in the following sections of this privacy notice:
1. HOW WE ARE REGULATED UNDER DATA PROTECTION LAWS
2. OUR USE OF YOUR PERSONAL DATA
3. WEBSITE USAGE AND DATA ANALYTICS
4. DATA RETENTION AND DATA SECURITY
5. OUR SHARING OF YOUR PERSONAL DATA
6. TRANSFERS OF YOUR PERSONAL DATA TO OTHER COUNTRIES
7. THIRD PARTY COLLECTION OF YOUR PERSONAL DATA
8. YOUR RIGHTS AND REQUESTS TO KONAMI
Please note that when we process your personal data in connection with providing you with specific products and services, then our other privacy notices may apply, as explained in Section 8 below. This privacy notice is intended to supplement our other applicable privacy notices and should be read together with them.
We may change, add to, or delete any part of this privacy notice from time to time. You can obtain the latest version of this privacy notice from [https://legal.konami.com/kdee/privacy_notice/].
As we operate our business through our UK Headquarters and our EU Branches, we will process your personal data in accordance with applicable UK, EU and national laws and regulations on data protection (collectively, “Data Protection Laws”). Data Protection Laws apply to our processing of your personal data as follows:
· Where our UK Headquarters is the controller of your personal data, the principal Data Protection Laws which we comply with are the UK Data Protection Act 2018 and the UK GDPR (being the GDPR (as defined below) as it applies in the UK after Brexit).
Our UK Headquarters is registered as a controller with the Information Commissioner’s Office (ICO registration number ZA029809), which is the Data Protection Authority in the UK (see Section 8 below). The EU’s GDPR may also apply to our UK Headquarters’ processing of your personal data in certain circumstances.
· Where one of our EU Branches is the controller of your personal data, the principal Data Protection Laws which we comply with are the General Data Protection Regulation 2016/679 (“GDPR”) and related national laws in the relevant EU Member States.
Our French branch acts as our main establishment under the GDPR for any cross-border processing of personal data within the EEA, and is based at 35 Rue Pierre Brossolette, Levallois Perret 92300, France. Our French branch has also been designated by our UK Headquarters as its GDPR representative in the EU for certain processing activities.
Processing Purposes
Depending on how we interact with you in the course of our General Business Activities, your personal data may be used for some or all of the following purposes:
· Customer Relationships: If you are a customer or end-user of our products and services, then we will use your personal data to manage our relationship with you, including to respond to any enquiries you make, for example when contacting us through our Customer Support services: https://eu-support.konami.com/hc/en-gb
· Business Operations and Commercial Relationships: If you are a representative of a company or other business or organisation with whom we have a commercial relationship, such as corporate customers, suppliers, distributors, journalists, intermediaries, professional advisors, agents and collaboration partners (collectively, our “Business Partners”) then we will use your personal data to operate, manage, develop and promote our business and, in particular, our relationships with you or the Business Partner you represent and related transactions. Examples of when we will process your personal data for such purposes include:
o To conduct discussions or negotiations with you in respect of prospective business, contracts or collaboration with you or the Business Partner you represent.
o To perform our obligations, receive or supply goods or services, or enforce our rights under a contract we have with you or the Business Partner you represent.
o To manage and deal with any dispute arising in relation to a contract with you or the Business Partner you represent.
o To communicate press releases and other updates on our products and services, and allowing permitted journalists and other press subscribers to access our press assets available via the Konami Press Room available at https://konami-assets.com/app/login?redirect=%2F
Collection of Personal Data
We may collect your personal data:
· Directly from you during the course of your interactions with us, such as when we contact you or you contact us.
· From our Business Partners.
· From publicly available sources (e.g. Companies House).
· From credit reference agencies (e.g. Experian).
Types of Personal Data
The types of your personal data collected may include some or all of the following:
· Identity Data: including your first name, middle name, last name, title, date of birth and gender.
· Contact Data: including your address (home or work address), telephone number and email address (personal or work), and country/region.
· Transaction Data: including details about the products or services purchased from or by you.
· Financial Data: including your bank account or other payment information.
· Employment Data: including who you work for if you are in contact with us on behalf of your employer.
· Support Data: information relating to your support enquiries including your Konami user ID/player name, user agent, contents of enquiries, correspondence history, information on billing and purchase history and order number, play data and linguistic information.
Lawful basis for processing
Where we have entered into a contract with you (e.g. where you provide services to us as an individual) then, to the extent that we need to process your personal data in order to perform our contract with you under the applicable contractual terms, our lawful basis is performance of a contract (Article 6(1)(b) UK GDPR/GDPR). In such cases, if you do not provide the personal data which we need in order to enter into or to perform a contract with you, then we may not be able to contract with you or to provide the services which you have requested.
In all other cases, our lawful basis for processing your personal data is that it is in the legitimate interests of Konami Europe to process your personal data in connection with managing our Customer Relationships and managing our Business Operations and Commercial Relationships, each as explained above (Article 6(1)(f) UK GDPR/GDPR).
Your right to object
Where we rely on legitimate interests to process your personal data for certain Processing Purposes, you have the right to object to our processing, as described below in Section 8.
If you are a visitor to our websites then we will use the Google Analytics service provided by Google LLC, together with certain other cookies provided by third party services, to collect certain standard technical and Internet log data about your visit to the website (“Technical Data”). We use such Technical Data principally for the following purposes:
· Website administration: including troubleshooting diagnosis, data analysis, testing, system maintenance, support, reporting and hosting of data.
· Data analytics: to analyse trends, track website visitor movements and gather broad demographic information to assist us in identifying visitor preferences and improve our website, products/services, customer relationships and experiences.
The Technical Data which we collect is processed by us in a way that does not directly identify anyone, and we will never try to find out the identities of visitors to our website.
For more information on the specific Google Analytics and other cookies we use, and how you can control them using your cookies preferences, please see our Cookies Policy.
Data retention
We keep your personal data for as long as it is necessary for the purpose which we collected it for, as explained in Section 2 above, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal data for a longer period:
· to the extent necessary to comply with applicable laws;
· in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you, or the company, business or organisation you represent; and/or
· where we have a legitimate interest to do so and where such retention is necessary for our legitimate interests.
If you require further information on specific retention periods then please contact us as explained in Section 8 below.
Data security
In accordance with Data Protection Laws, we have implemented (and require our service providers to implement) appropriate technical and organisational security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, damaged or destroyed, altered or disclosed.
We have also put in place reporting procedures to deal with any suspected personal data breach and will notify you and any applicable Data Protection Authority of a breach when we are legally required to do so.
Please contact us if you would like more information about these security measures using the contact details in Section 8 below.
We may share personal data with other companies or organisations for different reasons, as explained below.
Sharing with Konami Group Companies
We may share your personal data with other companies within the same group as us, including our parent company in Japan (Konami Group Corporation) and our affiliate company in the United States of America (Konami Digital Entertainment, Inc.) (the “Konami Group”).
In these cases, we will only share your personal data where it is necessary for our legitimate business interests and will ensure that any Konami Group companies that receive your personal data will use the personal data in accordance with, and within the scope permitted by, Data Protection Laws, this privacy notice and (where applicable) their respective privacy policies.
Sharing with service providers
We may also provide your personal data to our service providers both within the Konami Group and external third parties such as providers of the systems and services used to manage our Business Partners, to provide customer support, to manage our digital assets and press subscribers to the Konami Press Room, and to maintain our IT networks. We also use Google LLC for collecting Technical Data using Google Analytics, as explained in Section 2 above.
In every case, we will only use service providers in accordance with Data Protection Laws, by ensuring that:
· the service provider has appropriate safeguards in place to ensure the security and confidentiality of your personal data; and
· there is a written contract in place which protects your personal data and prevents it from being used for any purpose other than providing the relevant services.
Other sharing
We may also share your personal data with other third party companies as a result of the sale, merger, or reorganisation of Konami Europe or of Konami Group companies or business units which process your personal data, or in cases where we or relevant Konami Group companies are obliged to process or disclose the personal data by law or by order of a competent authority (e.g. a judge or court).
In connection with data sharing (see Section 5 above), we may transfer your personal data to companies located outside the UK or the EEA. We will only do this when the transfer is in compliance with Data Protection Laws, namely by ensuring that:
· the countries in which those companies are located have been deemed to provide an adequate level of protection for personal data by the UK or the EU (e.g. which is the case for transfers to Japan); or
· we have adopted and implemented Standard Contractual Clauses approved by the UK or the EU as appropriate safeguards for transferring your personal data lawfully outside the UK or the EEA.
Details of the relevant safeguards can be provided to you at your request by contacting us in accordance with Section 8 (Your rights and requests to Konami) below.
In some cases when we interact or communicate with you we may provide or include links to other third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites, plug-ins or applications and are not responsible for their use or collection of your data. We encourage you to read the privacy notice of every website, plug-in or application you visit.
Your rights under Data Protection Laws
Under certain circumstances, you have the following rights that you can exercise in respect of your personal data processed by the Konami Group companies.
· Information regarding your data processing: You have the right to obtain from us all the requisite information regarding our data processing activities that concern you (Articles 13 and 14 UK GDPR/GDPR).
· Access to personal data: You have the right to obtain from us confirmation as to whether or not personal data concerning you is being processed, and, where that is the case, access to the personal data and certain related information (Article 15 UK GDPR/GDPR).
· Rectification or erasure of personal data: You have the right to obtain from us the rectification of inaccurate personal data concerning you without undue delay, and to complete any incomplete personal data (Article 16 UK GDPR/GDPR). You may also have the right to obtain from us the erasure of personal data concerning you without undue delay, when certain legal conditions apply (Article 17 UK GDPR/GDPR).
· Restriction on processing of personal data: You may have the right to obtain from us the restriction of processing of personal data, when certain legal conditions apply (Article 18 UK GDPR/GDPR).
· Portability of personal data: You may have the right to receive your personal data in a structured and commonly used format, so you can transfer this data to another company. This only applies to personal data which we obtain from you and, using automated means, is processed on the basis of your consent or in order to perform a contract with you (Article 20 UK GDPR/GDPR).
· Object to processing of personal data: Where we rely on legitimate interests for processing your personal data for certain Processing Purposes (see Section 2 above), you have the right to object, on grounds relating to your particular situation, at any time to our processing of your personal data concerning you (Article 21 UK GDPR/GDPR). We must then stop processing your personal data unless we have a strong reason to continue such processing which overrides your objection.
Furthermore, when your personal data is transferred by Konami Europe from the UK or the EEA to a country outside the UK or the EEA, please contact us if you want further information on the specific mechanism relied upon for the transfer (e.g. adequacy finding or Standard Contractual Clauses).
How to exercise your rights
You can exercise these rights by contacting us at:
We try to respond to all personal data requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. Please also bear in mind that there are exceptions to the rights above and some situations where they do not apply.
We may need to request additional information from you to help us confirm your identity. This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you to clarify your request.
You will not normally have to pay a fee to access your personal data (or to exercise any of your other rights). However, we may charge a reasonable fee if your request is manifestly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.
How to communicate with us
You can communicate with us by the following methods:
Contact our Konami Group Data Protection Officer: We have appointed a Data Protection Officer (DPO), who has overall responsibility for looking after the Konami Group’s compliance with Data Protection Laws. You can contact our DPO by email at:
Contact Konami Europe directly: If you would prefer to contact Konami Europe directly in the UK or the EEA, you can do so by emailing our GDPR enquiries support service operated jointly by our UK Headquarters and our French branch at:
Your right to complain to a Data Protection Authority
Protecting your personal data is our priority and so if you believe that we have misused your personal data or violated any Data Protection Laws, then in the first instance we would always welcome you contacting us so that we can understand the nature of your concern and take the necessary steps to resolve your complaint and address your concerns.
Under Data Protection Laws, you have the right to file a complaint with a relevant Data Protection Authority, which will generally be the Data Protection Authority of your place of residence within the UK or the EEA.
In the UK, the Data Protection Authority is the Information Commissioner’s Office:
In the EEA, a list of the relevant Data Protection Authorities is available here:
https://edpb.europa.eu/about-edpb/board/members_en
If you have any inquiries of our products or services, you can contact us at:
https://www.konami.com/games/inquiry/
If you use other products and services offered by the Konami Group companies (e.g. entering a social media competition), or have other interactions with us (e.g. applying for a job), then your personal data will be processed in accordance with our other privacy notices, which currently include:
· Social Media Campaigns Privacy Notice
· Consumer Shows Privacy Notice
· Recruitment Privacy Notice & Supplementary Information
· Player Endorsement Privacy Notice
Last updated: July 2022