PRIVACY POLICY INSERT

FOR RESIDENTS OF CALIFORNIA, COLORADO, CONNECTICUT, MONTANA, OREGON, TEXAS, UTAH, AND VIRGINIA

Collection and Disclosure of Personal Information

The following chart details which categories of Personal Information we collect and process, as well as which categories of Personal Information we disclose to third parties for our operational business purposes, including within the 12 months preceding the date this Privacy Policy was last updated.

Categories of Personal Information		Disclosed to Which Categories of Third Parties for Operational Business Purposes
Identifiers, such as name, alias, postal address, email address, unique personal identifiers, online identifiers such as device ID, IP address, and Government ID number such as Social Security number, driver’s license number and passport number.		affiliates; service providers; social networks; marketing partners; joint businesses partners; industry associations; contest sponsors; legal authorities
Personal information as defined in the California customer records law, such as name, signature, postal address, telephone number, financial account or policy number, Government ID number such as Social Security number, driver’s license number and passport number, physical characteristics or description, professional or employment related information, medical information, financial information, and insurance information.		affiliates; service providers; social networks; marketing partners; industry association, joint businesses partners; contest sponsors; legal authorities
Characteristics of protected classifications under California or federal law, such as age, gender, medical conditions, marital status, sex race, disability, national origin.		affiliates; service providers; social networks; marketing partners; joint businesses partners; industry associations, contest sponsors; legal authorities
Commercial Information, such as purchase history and transaction information.		affiliates; service providers; legal authorities
Internet or network activity information, such as browsing history, search history and interactions with our online properties or ads.		affiliates; service providers; legal authorities
Geolocation Data, such as device location, and approximate location derived from IP address.		affiliates; service providers; legal authorities
Audio/Video Data. Audio, electronic, visual, thermal, olfactory, or similar information, such as photos, audio/video recordings.		affiliates; service providers; social networks; marketing partners; joint businesses partners; contest sponsors; legal authorities
Sensitive Personal Information.	Citizenship, immigration status, racial or ethnic origin.	affiliates; service providers; legal authorities
	Account log-in information (for our website/services).
	Contents of mail, email, and text messages unless Konami is the intended recipient of the communication.

We may also disclose your Personal Information to a third party in the event of any reorganization, financing transaction, merger, sale, joint venture, partnership, assignment, transfer, or other disposition of all or any portion of our business, assets, or stock (including in connection with any bankruptcy or similar proceedings).

We do not sell Personal Information, and we do not “share” or otherwise process Personal Information for purposes of targeted advertising, as defined under applicable law. We have not engaged in such activities in the preceding 12 months. Without limiting the foregoing, we do not sell or “share” the Personal Information of minors under 16 years of age.

Sources of Personal Information

We collect this Personal Information directly from you and from third-party sources, such as affiliates, business partners, public databases, joint marketing partners, tournament organizers, and social media platforms.

Purposes for the Collection and Use of Personal Information

We collect and use Personal Information to operate, manage, and maintain our business, to provide our products and services, and to accomplish our business purposes and objectives, including to:

· Develop, improve, operate, repair, and maintain our products and services;

· Provide customer support and respond to requests for information;

· Manage customer and supplier relationships;

· Advertise and market our products and services, and personalize user experiences;

· Conduct research, analytics, and data analysis;

· Operate and maintain our facilities and infrastructure;

· Undertake quality and safety assurance measures, and conduct security control and monitoring;

· Detect and prevent fraud and perform identity verification;

· Facilitate and implement any reorganization, financing transaction, merger, sale, joint venture, partnership, assignment, transfer, or other disposition of all or any portion of our business, assets or stock (including in connection with any bankruptcy or similar proceedings);

· Perform accounting, audit, and other internal functions, such as internal investigations; and

· Maintain records, comply with law, legal process, and internal policies, and exercise and defend legal claims.

Purposes for the Collection and Use of Sensitive Personal Information

Subject to your consent where required by applicable law, we may use Sensitive Personal Information for purposes of performing services for our business, providing goods or services as requested by you, ensuring security and integrity, short term transient use such as displaying first party, non-personalized advertising, order processing and fulfillment, servicing accounts, providing customer service, verifying customer information, processing payments, providing financing, and activities relating to quality and safety control or product improvement.

Retention Period

We retain Personal Information for as long as needed or permitted in light of the purpose(s) for which it was collected. The criteria used to determine our retention periods include:

· The length of time we have an ongoing relationship with you and provide services to you (for example, for as long as you have an account with us or keep using our services) and the length of time thereafter during which we may have a legitimate need to reference your Personal Information to address issues that may arise;

· Whether there is a legal obligation to which we are subject (for example, certain laws require us to keep records of your transactions for a certain period of time before we can delete them); or

· Whether retention is advisable in light of our legal position (such as in regard to applicable statutes of limitations, litigation or regulatory investigations).

Individual Requests

Subject to applicable law, you may make the following requests:

1. You may request to know whether we process your Personal Information, and to access such Personal Information.

a. If you are a California consumer, you may request that we disclose to you the following information covering the 12 months preceding your request:

i. The categories of Personal Information we collected about you and the categories of sources from which we collected such Personal Information;

ii. The business or commercial purpose for collecting Personal Information about you; and

iii. The categories of Personal Information about you that we disclosed, and the categories of third parties to whom we disclosed such Personal Information (if applicable).

2. You may request to correct inaccuracies in your Personal Information;

3. You may request to have your Personal Information deleted; and

4. You may request to receive a copy of your Personal Information, including specific pieces of Personal Information, including, where applicable, to obtain a copy of the Personal Information you provided to us in a portable format.

We will not unlawfully discriminate against you for exercising your rights under applicable privacy law.

To make a privacy request, please contact us at https://us-support.konami.com/ or 1-866-444-6528. We will verify and respond to your request consistent with applicable law, taking into account the type and sensitivity of the Personal Information subject to the request. We may need to request additional Personal Information from you, such as email address, phone number, full name, user ID/user name or address, in order to verify your identity and protect against fraudulent requests. If you maintain a password-protected account with us, we may verify your identity through our existing authentication practices for your account and require you to re-authenticate yourself before disclosing or deleting your Personal Information. If you make a request to delete, we may ask you to confirm your request before we delete your Personal Information.

Right to Opt-Out of Personal Information Sales and Sharing

You have the right to direct us to not sell or share your Personal Information for cross-context behavioral advertising purposes at any time (the "right to opt-out"). Please note that we do not currently engage in sales or sharing of Personal Information triggering such opt-out requirements.

Right to Limit Disclosure or Use of Sensitive Personal Information

You have the right to limit the disclosure or use of your Sensitive Personal Information that has been collected or processed with the purpose of inferring characteristics about you. Please note that we do not currently collect or use Sensitive Personal Information to infer characteristics about consumers triggering such limitation rights.

Appeal Process

If you are a Colorado, Montana, Oregon, Texas, Virginia, or Connecticut consumer, and we refuse to take action on your request, you may appeal our refusal within a reasonable period after you have received notice of the refusal. You may file an appeal by contacting us via https://us-support.konami.com/ or 1-866-444-6528.

Authorized Agents

If an agent would like to make a request on your behalf as permitted under applicable law, the agent may use the submission methods noted in the section entitled “Individual Requests.” As part of our verification process, we may request that the agent provide, as applicable, proof concerning his or her status as an authorized agent. In addition, we may require that you verify your identity as described in the section entitled “Individual Requests” or confirm that you provided the agent permission to submit the request.

De-Identified Information

Where we maintain or use de-identified data, we will continue to maintain and use the de-identified data only in a de-identified fashion and will not attempt to re-identify the data.

FOR RESIDENTS OF CALIFORNIA ONLY

California’s “Shine the Light” Law

If you are a California resident, you have the right to request certain information regarding our disclosure of your information to third parties for direct marketing purposes pursuant to Section 1798.83 of California Civil Code. If you request such information, please contact us at https://us-support.konami.com/hc/en-us/requests/new, with “California Privacy Rights” in the subject line.

California’ “Digital Online Erasure” Law

If you are a resident of California, under 18 and a registered user of our services, you may ask us to remove content or information that you have posted to the services by writing to https://us-support.konami.com/hc/en-us/requests/new. Please note that your request does not ensure complete or comprehensive removal of the content or information, as, for example, some of your content may have been reposted by another user.