CONSUMER SHOWS PRIVACY NOTICE – [ENGLISH VERSION]
FOR PARTICIPANTS, GUARDIANS & SPECTATORS
This 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”).
In this privacy notice, references to “you” or “your” mean an Event (as defined below) participant or spectator, or their Guardian (as defined below), as relevant from the context.
We may offer you the opportunity to participate in various online or offline events (“Events”) and to receive related services (collectively, “Event Services”). If you are under 18 years old, we may also need to process the personal data of your parent or legal guardian (“Guardian”) as described in Section 2.3 below.
The way in which we use and protect your personal data when you participate in, or attend and spectate at, Events, and use and receive our Event Services, 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
2.3.... Guardians of Event participants and spectators
3....... DATA RETENTION AND DATA SECURITY
4....... OUR SHARING OF YOUR PERSONAL DATA WITH OTHER COMPANIES
5....... TRANSFERS OF YOUR PERSONAL DATA TO OTHER COUNTRIES
6....... YOUR RIGHTS AND REQUESTS TO KONAMI
7....... OTHER PRIVACY NOTICES
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 7 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 6 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 the type of the Event you participate in, your personal data may be used for some or all of the following purposes (“Event ParticipationPurposes”) in order to provide Event Services:
i. contacting you with regard to your participation in the Event;
ii. running the Event;
iii. introducing the Event participants in announcements and broadcasts of the Event, or promotion, publicity and advertising for related goods and services;
iv. arranging air flights or other transport, accommodation, and other travel related matters;
v. reporting the results, statistics and analysis of the Event (including on Konami digital channels);
vi. (where relevant) updating and managing your Event results for your Konami Card Game ID account;
vii. distributing/streaming the Event on the Internet (live and/or recorded);
viii. keeping records of the Event;
ix. publishing participant and spectator interviews (live and/or recorded, written and audio-visual);
x. shipping of prizes;
xi. communicating with you during, and after, the Event in connection with possible penalties, disqualification and/or suspension from future Events;
xii. handling any enquiries or complaints from you before, during or after the Event; and
xiii. other purposes which are directly related to providing and improving the Event Services including developing products and services related to the subject matter of the Event.
Types of personal data
We collect your personal data in connection with providing you with Event Services which may include some or all of the following:
i. Contact data: home address, first name, middle name, last name, phone number, email address;
ii. Konami game play data: Konami Card Game ID, Konami ID, information included in questionnaires and game records (including information on documents relating to possible penalties, disqualifications and/or suspensions and prize shipping forms);
iii. Audio-visual data: photographs, videos and other recordings of you (including audio of your voice and Event live streaming);
iv. Travel and country/nationality data: passport number and other passport details, language, nationality; and
v. Other types of identifying data: signature, age, place and date of birth, location.
Lawful basis for processing
The lawful basis for Konami Group companies to process your personal data in connection with providing you with Event Services is that it is necessary for our legitimate business interests in providing, as well as for your interest in receiving, Event Services, for the Event Participation Purposes set out above (Article 6(1)(f) UK GDPR/GDPR).
In cases where certain personal data is necessary for providing any of the Event Services and you choose not to submit it, we may not be able to begin or continue to provide such services to you (e.g. without submission of your real name and passport details we cannot make any travel arrangements).
Your right to object
As we rely on legitimate interests to process your personal data for the Event Participation Purposes, you have the right to object to our processing, as described below in Section 6 (Your rights and requests to Konami).
Processing purposes
Depending on the type of the Event you are spectating or participate in, your personal data may be used for some or all of the following purposes (“Event SpectatorPurposes”) in order to provide Event Services:
i. running the Event;
ii. reporting the results, statistics and analysis of the Event (including on Konami digital channels);
iii. distributing/streaming the Event on the Internet (live and/or recorded);
iv. keeping records of the Event;
v. publishing participant and spectator interviews (live and/or recorded, written and audio-visual);
vi. handling any enquiries or complaints from you during or after the Event; and
vii. other purposes which are directly related to providing and improving the Event Services including developing products and services related to the subject matter of the Event.
Types of personal data
We collect your personal data in connection with providing you with Event Services which may include some or all of the following:
i. Audio-visual data: photographs, videos and other recordings of you (including audio of your voice and Event livestreaming); and
ii. Contact data: (if you provide this to us, for example when making an enquiry or complaint at or after the Event) including home address, first name, middle name, last name, phone number, email address.
Lawful basis for processing
The lawful basis for Konami Group companies to process your personal data in connection with providing you with Event Services is that it is necessary for our legitimate business interests in providing, as well as for your interest in attending Events and (where applicable) receiving other Event Services, for the Event Spectator Purposes set out above (Article 6(1)(f) UK GDPR/GDPR).
In cases where certain personal data is necessary for providing any of the Event Services and you choose not to submit it, we may not be able to begin or continue to provide such services to you (e.g. if you do not wish us to take photos or make video or livestreaming footage of the Event then you should not enter the Event area).
Your right to object
As we rely on legitimate interests to process your personal data for the Event Spectator Purposes, you have the right to object to our processing, as described below in Section 6 (Your rights and requests to Konami).
Processing purposes
If you are the Guardian of a minor receiving Event Services, your personal data may be collected and used for some or all of the following purposes in connection with the minor’s receipt of the Event Services (“Guardian Processing Purposes”):
i. contacting you parent/guardian for the confirmation of the minor’s name, date of birth, age, contact details and participation in any Event;
ii. running Events in which the minor participates;
iii. arranging air flights and other transport, accommodations, and other travel related matters involving the minor;
iv. distributing/streaming the Event on the Internet (live and/or recorded) including footage of the minor;
v. publishing participant and attendee interviews (live and/or recorded, written and audio-visual) including recordings of the minor; and
vi. handling any enquiries or complaints from you before, during or after the Event.
Types of personal data
We collect your personal data in connection with providing the minor with Event Services which may include some or all of the following:
i. Contact data: home address, first name, middle name, last name, phone number, email address;
ii. Audio-visual data: photographs, videos and other recordings of you (including audio of your voice and Event live streaming);
iii. Travel and country/nationality data: passport number and other passport details, language, nationality; and
iv. Other types of identifying data: signature, age, place and date of birth, location.
Lawful basis for processing
The lawful basis for Konami Group companies to process your personal data in connection with providing the minor with Event Services is that it is necessary for our legitimate business interests in providing, as well as for the minor’s interest in receiving, Event Services for the Guardian Processing Purposes set out above (Article 6 (1)(f) UK GDPR/GDPR).
In cases where certain personal data is necessary for providing the minor with Event Services and you choose not to submit it, we may not be able to begin or continue to provide certain Event Services to the minor (e.g. without submission of your name and contact details we may not be able to contact you for any necessary approvals for the minor to participate in Events).
Your right to object
As we rely on legitimate interests to process the minor’s personal data for Event Participation Processes, and your personal data for Guardian Processing Purposes, you have the right to object to such processing on your own behalf or behalf of a minor where they are unable to do so themselves, as described below in Section 6 (Your rights and requests to Konami).
Data retention
We keep your personal data (including personal data of your Guardian) until the end of each Event and for as long as is necessary: (i) following the Event in order to complete the provision of Event Services to you (for example, shipping prizes to you following the Event); and (ii) for the purpose which we collected it for, as explained in Section 2 above, including for the purposes of satisfying legal, regulatory, tax, accounting or reporting requirements.
We may keep your personal data following the Event where we have a legitimate interest to do so. For example:
i. content (including photographs, videos and audio) from, and reporting of, the Event may be published on the Internet (including on Konami’s websites and social media channels) for so long as it remains relevant or of interest to Event participants and other customers, fans and followers of the relevant part of Konami Europe’s business;
ii. information relating to any possible penalties, disqualification and/or suspension will be kept for the appropriate period of time for as long as that information remains relevant (e.g. until an investigation has been conducted or the player is reinstated); and
iii. personal data may be retained and used for up to 5 (five) years for analytics and reporting purposes.
We may retain your personal data for a longer period
i. to the extent necessary to comply with applicable laws;
ii. in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you; and/or
iii. 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 6 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 6 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 Japan (Konami Group Corporation) and our affiliate company in the United States of America (Konami Digital Entertainment, Inc.) (the “Konami Group”).
In these cases, 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 personal data to our service providers both within the Konami Group and external third parties such as Organised Play Partners, travel agencies, shipping agents and couriers, content broadcast providers, Event reporters, PR and marketing agencies, distributors and, providers of ranking calculation software, social media and livestream channels (e.g. YouTube, Facebook, Twitch, Instagram and Twitter), and providers of the online tournament pairing system and websites of the Konami Group companies.
In every case, we will only use service providers in accordance with Data Protection Laws, by ensuring:
i. the service provider has appropriate safeguards in place to ensure the security and confidentiality of your personal data, and
ii. 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 the Konami Group companies or business units that 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 4 above), we may transfer your personal data to other 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:
i. 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 Japan); or
ii. 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 6 (Your rights and requests to Konami) below.
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: As we rely on legitimate interests for processing your personal data for the Event Participation Purposes, the Event Spectator Purposes and (where applicable) the Guardian 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).
You can exercise the above 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.
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:
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