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Sega of America, Inc. Privacy Policy
 
Effective Date: June, 2021
Version: 2021.01
 
Interest Based Ad Disclosure
Precise Location Data Disclosure
 
Introduction
 
Sega of America, Inc., its subsidiaries and affiliates (together “SEGA”, individually a “SEGA Entity”) are committed to protecting the privacy and security of your personal data. SEGA collects different types of information from you when you use our mobile, online and downloadable products and services (together, the "Products").
 
This Privacy Policy explains how we collect, use and protect your personal data when you use our Products or interact with us.
 
By using our Products you acknowledge that you have read and understood the terms of this Privacy Policy, including how we use your personal data.
 
The data controller is responsible for collecting and using your personal data.  To comply with data protection legislation, the data controller will be the SEGA Entity with whom you contract for a Product. See the 'Your questions and how to contact us' section of this Privacy Policy for more details.
 
Sega of America, Inc. is a valid licensee and participating member of the Entertainment Software Rating Board’s Privacy Certified Program (“ESRB Privacy Certified”). To help protect your privacy, we have voluntarily undertaken this privacy initiative and have had all of the Products where this privacy policy and an ESRB Privacy Certified seal are displayed, reviewed and certified by ESRB Privacy Certified to meet established online data collection, use and disclosure practices. As a licensee of this privacy program, we are subject to audits of our Products and other enforcement and accountability mechanisms administered independently by ESRB Privacy Certified. In addition, for U.S. users of our Products, we adhere to the Digital Advertising Alliance’s Self-Regulatory Principles for the Mobile Environment.
                                                                                                                
We reserve the right to update this Privacy Policy from time to time by changing it as it applies to your use of any of our Products. We want you to enjoy using our Products and urge you to follow common sense whenever disclosing personal data – in our Products or elsewhere.
 
________________________________________________________________________
 
Summary
 
Our Privacy Policy will help explain what information we collect, how we use it and what options you have in relation to it. The key points of our Privacy Policy are provided below, however you can also learn more by clicking the ‘learn more’ link below.
 
We will only collect and process personal data about you where we have a lawful basis in your country. As stated throughout this Privacy Policy, our lawful bases include consent (where you have given consent to, say, receive updates and marketing emails), contract (where processing is necessary for the performance of a contract with you (e.g. to supply the Products you have requested)) and “legitimate interests”.
 
 
1. Information we collect and receive

We collect personal data about you and the devices you use to access and interact with us and our Products. We collect:

(a) Registration information:  
     you give us when you sign up to access our Products 
(b) Billing information:  
     provided by you and/or third party stores
(c) Technical and device information:
     information from your mobile or computer device when you use our Products
(d) Feedback / surveys / user research:
     your questions, suggestions or views on our Products
(e) Third party information:
     information about your use of our Products that is shared with third party platforms and services connected with our Products.
    We also receive data about you from partners to improve the performance of our Products
(f) Information from publicly available online sources:
    information that has been made publicly available by you on third party platforms (such as Facebook or Twitter) and which relates to our Products
(g) Information about your use of our Products:
     information we collect when you use our Products
(h) Sweepstakes:
     information you provide to us when you participate in our sweepstakes
(i) Social media plug-ins:
    information that is collected when you utilise third party social media plug-ins relating to our Products
(j) Anti-cheat and anti-hacking technologies:
   information that helps us to ensure our Products are used in a fair and lawful manner
(k) LiveOps software:
    information that is processed by third party LiveOps tools when you use our Products
(l) User Acquisition and Core / Custom / Lookalike Audiences:
    information that is collected to help us acquire new users for our Products and to build Custom and Lookalike Audiences

 

Learn more

 

2. Our use of collected information
Collected information may be used in the following ways:
 
(a) Registration information:
(i) to create your profile and so you can access our Products;
(ii) to identify you when you sign-in;
(iii) to give you access to your user preferences;
(iv) to contact you for your views on our Products;
(v) to notify you of changes or updates to our Products; and
(vi) for marketing purposes, based on your communication preferences.
 
(b) Billing information:
(i) to verify your purchase of our Products and process any refunds;
(ii) to reply to any queries and questions and to resolve problems;
(iii) to carry out analysis and research to develop our Products; and
(iv) to protect you and our Products by seeking to detect and prevent fraud or other acts in breach of our user agreements or policies relevant to our Products.
 
(c) Technical and device information:
(i) to provide you with an optimal experience;
(ii) to understand how you interact with our Products
(iii) to provide Products you request; 
(iv) to measure and analyse the use and effectiveness of our Products;
(v) to understand which of your devices are using our Products;
(vi) to provide safe and fair gaming environments;
(vii) to customise and optimise the targeting of our advertising both within our Products and across our websites;
(viii) to operate and improve our Products; and
(ix) to fix errors.
 
(d) Feedback / Surveys / User Research:
(i) to reply to your questions or queries;
(ii) to record comments and information which you provide on our gaming forums; and
(iii) to conduct analysis and research to improve and develop our Products.
 
(e) Third party information:
(i) to enable us to provide tailored offers to you;
(ii) to facilitate sharing on social networks; and
(iii) to facilitate your gameplay.
 
(f) Information from publicly available online sources:
(i)to understand the community sentiment about our Products;
(ii)to understand how you engage with our marketing campaigns; and
(iii)to gain an understanding of community sentiment about our Products.
 
(g) Information about your use of our Products:
(i) to track the performance of our Products;
(ii) to communicate with our platform operators and partners; and
(iii) to improve our advertising and targeting systems.
 
(h) Information about your participation in sweepstakes:
(i) to verify your identity; and
(ii) to distribute prizes to you.
 
(i) Information about your use of social media plug-ins:
(i) to allow you to easily share our content via social media platforms.
 
(j) Information from anti-cheat and anti-hacking technologies:
(i) to detect illegal or malicious activity in our Products.
 
(k) Information from live-ops software:
(i) to provide certain in-game features and functionality.
 
(l) Information for User Acquisition and Core / Custom / Lookalike Audiences:
(i) to acquire new users for our Products and help us build Core, Custom and Lookalike Audiences for analytics and marketing purposes.
 
Learn more
 
3. When we share information
 
We may share the information we collect about you (subject to the necessary security, contractual and transfer safeguards).  These are some of the partners we may share your personal data with:
(a) SEGA companies within the wider SEGA group;
(b) Third party platform operators such as Valve who operate the Steam digital download platform, Epic, Apple, Google Play, Amazon, Samsung, Sony PlayStation, Nintendo, Microsoft Xbox, and other partners who carry out various activities and services to support our Products (collectively, the “Platform Operators”);
(c) Advertising partners for the service of advertisements within our Products.
(d) Marketing partners for marketing or promotions such as Mailchimp, based on your communication preferences;
(e) New owners or re-organised entities and their advisors in the event of a business restructure, sale, purchase or joint venture affecting our business; and
(f) Law enforcement agencies/authorities, when we are under a duty or are authorised by law for law enforcement purposes.
 
Your personal data may be transferred to other countries where SEGA or its service providers maintain operations. These countries may not have equivalent data protection laws to the country from where you access our Products, but we will ensure that we rely on appropriate safeguards.
 
Learn more
 
4. Security and data retention
Your privacy is important to us and we place great importance on the steps we take, including technical and organisational measures to protect your information from unauthorised access and against unlawful processing, accidental loss, destruction and damage.
 
Your personal data will be kept by SEGA for the duration of your relationship with us and for as long as you use our Products and may be retained for a period after this time if it is necessary and relevant to our legitimate operations, under our terms with you and in accordance with applicable laws.
 
Learn more
 
5. Your choices and rights
 
You have options and choices over how we use your personal data. You may be required to register or sign in to use or access some of our Products, and may need to provide personal data to create a user profile which is associated with your use of our Products.
 
If you wish to amend the personal data that you use to access our Products; object to our processing of your personal data;  or would like us to correct, erase, restrict, or move your personal data, you can contact us using the details below. If you do not want us to process and/or access your personal data, you may be unable to use some of our Products.
 
If you sign up to our marketing communications, you will be asked to confirm your communication preferences and will be given the opportunity to unsubscribe at any time.
 
Learn more
 
6. Children’s information
 
Protecting the privacy of young children is especially important to SEGA. For that reason, SEGA does not knowingly collect or maintain personal data or non-personally identifiable information from underage users other than as permitted by law in support of our internal operations.
 
In this privacy policy any reference to underage users refers to those under the age of consent to the processing of personal data in their country of residence:

• Croatia, Germany, Hungary, Ireland, Luxembourg, Malta, Netherlands, Poland, Romania, Slovakia - 16 or under
• Czech Republic, France, Greece, Slovenia - 15 or under
• Austria, Bulgaria, Cyprus, Italy, Lithuania, Spain - 14 or under
• United States, United Kingdom and any EU countries not listed above - 13 or under

 
Learn more
 
7. California Residents
 
The California Consumer Privacy Act 2018 (the “CCPA”), Privacy Rights for California Minors in a Digital World and the California Shine the Light law provide California residents with certain rights regarding the processing of their personal data.
 
Learn more
 
8. Nevada Residents
Nevada law provides Nevada residents with certain rights regarding the processing of their personal data.
 
Learn more
 
9. Mobile Applications
Several of our mobile products serve advertising, and some of our partners collect data directly from your device. Depending on your region and device, you can control our partners’ access to data.
 
Learn more
 
10. Your questions and how to contact us
If you have any questions or comments about this Privacy Policy you can contact us.
 
Contact details
____________________________________________________________________
More information
 
1. Information we collect
We collect personal data about you and the devices you use to access our Products and interact with us. We collect:
 
(a) Registration information
 
When you register or sign up to use our Products (or a SEGA account associated with our Products, such as Games2Gether) we may collect information about you including your name, contact details, age, gender, personal preferences and additional information that you chose to provide. You may be required to register with your Platform Operator account ID to use certain features within our Products. We may also collect your contact information so that you can sign-up to receive SEGA's marketing communications. We use tracking pixels in our marketing communications so that we can verify if the e-mail has been opened. As part of any required sign in to use our Products, we will verify the information that you use to log in.
 
You can choose to sign-up for our Products using third party services such as your Facebook account in which case Facebook will ask you for permission to provide certain personal data such as your username, date of birth and contact details.
 
(b) Billing information
 
We may collect payment information such as credit or debit card details (including expiration dates) and other billing information such as your name and address. We may collect this information from you and/or third party stores that have been authorised to sell our Products.
 
(c) Technical and device information
 
By accessing our Products, we may collect technical information from your mobile or computer device, for example your location information where you choose to share this with us, which devices are connected to the Internet, hardware settings, components of your devices, installed software, updates and plugins to facilitate the use of our Products. We may automatically collect information such as your operating system, IP address (the unique address which identifies your device on the internet), your browser type, browser language preferences and when, how often and how long you interact with our Products, websites and services. We, and/or our third party suppliers may use cookies and similar technologies (including but not limited to web beacons and tracking pixels), or collect data about your device(s) to create a device fingerprint of the components of your specific device(s).
 
See also our Cookies Policy
 
(d) Feedback / surveys / user research
 
We will collect personal data from the messages and reviews you post on our social channels and forums, or on the Games2Gether platform, and when you contact us, for example with a question, problem or comment. Telephone support through our customer services department is automated and we do not collect your personal data.  If you contact our customer services team by email or through our third-party ticketing system (Zendesk), we will keep copies of your correspondence with us for as long as necessary to deal with your query.
 
If you decide to participate in our surveys, you may be asked to provide personal data such as your name, age, location (country or US state), gender and e-mail address (also optional information about your gaming platforms and habits).
 
From time to time, SEGA carries out user research testing sessions to obtain feedback from our customers about our Products. By participating in these sessions, you may be asked to provide your personal data including your name, address, age, location (country or US state), gender and email address (also optional information about your gaming platforms and habits). SEGA may also film and record these sessions.
 
(e) Third party information
We share information obtained about your use of our Products with certain third party partners. The information may include anything outlined in Section 1: Information We Collect. Examples of this include sharing data on your gameplay patterns with game development partners.
 
We also receive data about you and your use of Products from Platform Operators, including sales data and gameplay data related to your interactions with our Products, including player performance statistics, in-game actions, character options, and other similar in-game data.
 
(f) Information from publicly available online sources
 
SEGA uses its own and third-party analytic technologies to collect information about how you use our Products.  In doing so, we may collect and analyse information which has been made publicly available by you through third party platforms such as Facebook, Twitter, Reddit and public forums. The data that SEGA collects may include a Facebook comment, a Tweet or a post on a public forum, where these specifically relate to our Products.
 
(g) Information about your use of our Products
 
We collect information from your web browser about the way you use our Products. We may also collect information about you from the notifications or messages you post or send online as well as what you search for, look at and engage with. Information obtained from social features used within our Products, such as in-game communications, forums and chat functionality, may be stored, copied or used by SEGA, the public, or third-party companies.
When you visit or use our Products we collect, process and combine information about your use of those Products, such as your IP address, Platform Operator account information (e.g. the pseudonymised user ID associated with your Xbox or Steam account), hardware and software information, and aggregate gameplay data, usage data and purchase histories.      We also receive data about you and your use of our Products from Platform Operators, including but not limited to sales and gameplay data related to your interactions with our Products.
 
(h) Information about your participation in sweepstakes
 
When you participate in a sweepstake organised by SEGA, you may be asked to provide certain personal data, such as your name, email address, country of origin and the User ID for the Platform Operator which you use to access our Products (e.g. Steam ID). You may also be required to submit a photograph or video of yourself if this forms part of the entry requirements of the sweepstake.
 
Winners may be required to provide their address for the purpose of SEGA delivering the prizes.  Where cash prizes are awarded, you will be prompted to register with our authorised third-party partner that will handle the issuing of the prize payments on our behalf.
 
The sweepstake you participate in will have its own terms and conditions which will set out the specific requirements in more detail.
 
(i) Information about your use of social media plug-ins
 
Some SEGA websites may include social media plug-ins. These plug-ins allow you to easily share our content via social media platforms such as Facebook and Twitter, most commonly via a “share” or “like” button.
 
Whenever you launch a SEGA web page that contains a social media plug-in, your browser establishes a connection with the servers of that social media platform. If you decide to utilise the plug-in, by “sharing” or “liking” the content on our website, that data will be shared with the social media platform via your browser.
 
(j) Information from anti-cheat and anti-hacking technologies
 
SEGA strives to ensure that anyone who interacts with our Products, or participates in our competitions and tournaments, does so in a fair and lawful manner. SEGA may utilise anti-cheat and/or anti-hacking technologies to collect certain personal identifiers relating to your use of our Products.
 
(k) Information from live-ops software
 
If you play a Product that utilises live-ops software, that third party software will collect certain personal data about you as required by that service. This personal data will be processed and stored in accordance with the third party’s privacy policy. The software may also allow SEGA to collect data analytics relating to your use of the Product.
 
Examples of data that may be collected include a unique user account ID, IP address, how often you play, your progress through the game and information about your gaming device.
 
(l) Information from User Acquisition and Core / Custom / Lookalike Audiences
 

We may share your personal data with Facebook, Google, Twitter and other third-party partners for marketing purposes (which may involve acquiring new users for our Products) and to help us build Core Audiences, Custom Audiences and Lookalike Audiences. We will only share your data (typically a device ID or an e-mail address) with these partners in accordance with regulations in your region.
 
2. How we use the information we collect
 
We use the personal data we collect for the following purposes:
 
(a ) Registration information
 
Your registration information enables us to create your profile, provide you with access to our Products and to give you access to your user preferences. This is necessary for the purpose of performing the contract we have with you. It helps us to authenticate your access, to contact you for your views and to notify you of important changes or updates to our Products.  
 
If you choose to sign-up for our Products using third party services such as your Facebook account, Facebook may share your personal data with us subject to Facebook's privacy policy and the privacy settings of your Facebook account.  This may also enable Facebook and us to link your activities with your personal registration information at their site, and may include notifying your friends about your activities whilst using our Products. If you sign-up via third party services you should visit the third party website and review their privacy policy and your registration profile or account to understand how your data is processed by them and to find out what your options are.
 
Where we have your consent and in accordance with your stated communication preferences, we may also contact you for marketing purposes to let you know by email, telephone, mobile or in-app messaging about our other products and services.
 
If you no longer want us to use your personal data in this way or generally change your mind about receiving marketing communications, you can unsubscribe at any time, either by using the unsubscribe option in the communication you receive or by changing your communication settings. By unsubscribing from marketing communications, you will be opted out of our e-mail/marketing tracking pixels. Please note that we will retain a record of the user information when you unsubscribe from our marketing information for the legitimate purpose of ensuring that we do not contact you further in this way, during the period of your objection, if relevant.
 
(b ) Billing information
 
This information will enable us to verify your purchases with third party stores and to contact you in order to assist with resolving any problems with your purchases and to process any refund payments that you may be due.
 
We will also use and analyse information on transactions on your account for our legitimate interests by data matching or statistical analysis so that we can administer, support, improve and develop our business and to help us detect and prevent fraud, or other illegal activities, or acts prohibited by our terms of service or any policies applicable to our Products.
 
(c) Technical and device information
 
We use internet log files to monitor traffic on our Products, resolve technical problems and to detect and prevent fraud. 
 
We use technical and device information to provide us with information, such as when an email is opened, or to develop statistics on the effectiveness of advertising or marketing on our websites. In some cases, working with third-party partners, we use this information to send you ads for our Products based on your interests.
 
We also use technical and device information to operate and improve our Products, enable online matchmaking, facilitate sharing, measure our effectiveness, set up and maintain accounts, identify and fix errors and to help keep online content fair and safe and to resolve related disputes.
 
(d) Feedback / surveys / user research
 
We use your feedback to reply to your questions or queries, to provide customer support and resolve problems relating to any of our Products. We will also publish reviews about our Products that you submit to us for this purpose and will conduct analysis of feedback for the purpose of improving and developing our Products.  SEGA may also film and record user research sessions so that we can observe your playing habits and record your feedback.
 
SEGA uses the information collected during surveys and user research sessions to help us to tailor and improve our Products.
 
SEGA may share data from user research sessions with certain third-party partners where there is a legitimate business requirement to do so. In such circumstances, your data will always be fully anonymised before it is shared.
 
(e) Third party information
 
We share information obtained from your use of our Products with third parties to provide you with an optimal experience, to facilitate use of our Products as advertised and to enable you to play our Products on various gaming platforms.
 
We also receive data about you and your use of Products from Platform Operators, which we use to track the sale and performance of our Products and to help us to improve certain aspects and features within our Products.
 
We may use analytics technologies to link your online activities so that we can serve targeted ads.  Valve (the Platform Operator for the Steam digital download platform) may for example share pseudonymised Steam IDs with us to help optimise our offerings to you and to help us understand how you are using our Products. Again, if Valve shares this information with us it does so subject to its privacy policy, and the privacy settings of your Steam account.
 
We may also work with advertising networks that serve advertisements into our Products, or the websites and products of third parties. Some of those advertisements may be personalised to your interests based on your activity and technical information and/or use data contained within the cookies which are stored on your device (subject to data regulations in your region). For Mobile Applications, please see section 9 of this privacy policy.
 
Our third party partners may also use other technologies (such as cookies, JavaScript, or web beacons) to measure the effectiveness of their advertisements and to personalise the advertising content you see. See also our Cookies Policy.
 
We may also bring you advertising content in certain Products, which you would traditionally see in a live game environment, for example perimeter advertising in a football game. For example, our Football Manager PC/Mac Product is currently supported by Bidstack, a platform that enables Third Party Advertisers to dynamically serve in-game native billboard advertising within video games.
 
We may also provide functionality within our Products which enables you to upload gameplay footage to YouTube. If you choose to use this feature, we will receive and store an authentication token from Google so that the feature will operate properly.  The use of this functionality is governed by YouTube’s Terms of Service: https://www.youtube.com/static?template=terms.  Further information about the protection of your privacy can be found in Google’s privacy policy: https://policies.google.com/privacy?hl=en-US. You can also view and modify your permissions via Google’s security settings: https://myaccount.google.com/permissions.
 
(f) Information from publicly available online sources
 
We will use and analyse this data for our legitimate interests so that we can collect information about how you use our Products, how you engage with our marketing campaigns and to gain an understanding of community sentiment about our Products.  We may use third party analytics providers who collect this data on our behalf.  Where possible, we will ensure that any personal data that is collected for these purposes is anonymised.
 
(g) Information about your use of our Products
 
This information enables us to track the performance of our Products, develop new Products and communicate with our Platform Operators and partners. It also enables us to better understand our users and improve our advertising, targeting and measurement systems.
 
We analyse information about how you engage with our Products to understand how our Products are used and to provide you with an optimal gaming experience, such as by rolling out performance-optimising software updates for our Products.  We use this data in order to analyse and produce statistics relating to the habits, usage patterns and demographics of users as a group or as individuals.  This allows us to deliver you customised content, helps us understand the features of our Products that appeal to you and allows us to manage advertising, amongst other things.
 
(h) Information about your participation in sweepstakes
 
SEGA collects and processes this data for the purposes of running and monitoring the sweepstake, as well as for carrying out publicity activities relating to the competition.
 
Your personal data will be retained by SEGA for the duration of the sweepstake and for a period after this time as necessary to deliver the prizes (if applicable).
 
(i) Information about your use of social media plug-ins
 
Once your data has been shared with the social media platform (acting as a joint controller of your data), your interactions with these features are governed by the privacy policies of the relevant platform. More information about their privacy practices can be found at the following links:
 
https://www.facebook.com/about/privacy/
https://twitter.com/en/privacy
 
(j) Information from anti-cheat and anti-hacking technologies
 
SEGA may utilise anti-cheat and/or anti-hacking technologies to help us to detect illegal or malicious activity and to take the appropriate actions if such activity is detected.
 
The anti-cheat/hacking technologies within your Product may require you to download certain data to your device. If you disable or otherwise tamper with these technologies, the Product may not operate properly and you will be in breach of the applicable end user license agreement.
 
(k) Information from live-ops software
 
Our Products may include third party live-ops software which helps us to provide in-game features that are core to your gameplay experience. For example, the software may enable us to offer multiplayer modes, leader boards, in-game rewards and more.  
 
(l) Information for User Acquisition and Core / Custom / Lookalike Audiences
 
We use various forms of marketing to acquire new users for our Products, working with a variety of third party partners to deliver our marketing campaigns and serve advertisements on external websites and social media platforms. As part of this, we may share certain data with our user acquisition partners.
 
If your data has been shared with our partners (subject to data regulations in your region), you will receive targeted ads when you use the internet or play our Products (our Custom Audience).  Other users of those platforms who share similar interests to you may also receive targeted ads about our Products (our Lookalike Audience).

Further information about the protection of your privacy can be found in the relevant social platform’s privacy policy. For links to these, and details of partners who are integrated into our mobile titles and websites, please see Appendix A of this privacy policy.
 
3. When we share information
 
In delivering our Products to you, we may share your personal data with:

• Companies within the SEGA group (which means SEGA Entities which are our parent and affiliated companies, our ultimate holding company and its subsidiaries and affiliates) who act for us for the purposes set out in this policy.
• Third party service providers in order to undertake various activities or services on our behalf in supporting our Products. This includes payment processing providers facilitating credit and payment card transactions, website and application support and hosting providers for online videogame services and software downloads and providers for the delivery of promotional, digital advertising or other communications, such as MailChimp. See also Section 9 - Mobile Applications.
• If our business enters into a joint venture, purchases or is sold to or merged with another business entity, your information may be disclosed or transferred to the target company, or new business partners or owners or their advisors.
• We may use the information that you provide if we are under a duty to disclose or share your information in order to comply with (and/or where we believe we are under a duty to comply with) any legal obligation; or to enforce the relevant terms of service and any other agreement; or to protect our rights or the rights of third parties. This includes exchanging information with other companies and organisations such as credit agencies, law enforcement or government bodies or the courts in connection with a criminal investigation, suspected illegal activity, fraud prevention and detection or in legal proceedings.

Personal data may be transferred to other countries where SEGA or its service providers maintain operations. These countries may not have equivalent data protection laws to the country from where you access our Products or, in the case of transfers subject to European law, may not be subject to an adequacy decision by the European Commission (EC).   An adequacy decision is a decision taken by the EC establishing that a third country provides a comparable level of protection of personal data to that in the EU, through its domestic law or its international commitments.
 
Where SEGA transfers personal data it will seek to take account of any applicable legal obligations relevant to personal data transfers.  In the case of transfers of personal data out of the European Economic Area,  it will, in the absence of an EC adequacy decision relevant to the destination country, seek to rely on appropriate safeguards such as the EC approved standard contractual clauses relevant to personal data transfers between data controllers or between a data controller and a data processor (see http://ec.europa.eu/justice/data-protection/international-transfers/transfer/index_en.htm).
 
4. Security and data retention
 
We place great importance on the steps we take, including physical, technical and organisational measures, to protect your information from unauthorised access and against unlawful processing, accidental loss, destruction and damage.
 
Where you have chosen a password which allows you to access any of our Products, you are responsible for keeping this password confidential. We advise you not to share your password with anyone. We will not be liable for any unauthorised transactions entered into using your personal data, including but not limited to your username, and/or password. If you suspect unauthorised access, you should change your password, using a strong password immediately.
 
Your personal data will be retained by us for the duration of your use or access to our Products and may be retained for a period after this time as necessary and relevant to our legitimate operations, our terms with you and in accordance with applicable laws and obligations. This may include retention necessary to meet our tax reporting requirements as well as time required to enforce any obligations in our agreements, any game “sun-setting” requirements or to identify, issue or resolve legal proceedings. 
 
We may retain a record of your stated objection to the processing of your data, including in respect of an objection to receiving marketing communications, for the sole purpose of ensuring that we can continue to respect your wishes to not contact you further, during the term of your objection.
 
We will take appropriate steps to seek to destroy or permanently de-identify personal data at the point this information is no longer needed by us for our business or legal purposes.
 
For more information about exercising your rights with respect to our data processing activities, or if you no longer wish to use our Products, see details below about your choices and rights.
 
5. Your choices and rights
 
You have options and choices over how we use your information. We provide you with tools to access and update specific information relating to your use of our Products at any time. If you need to sign in to access certain Products, you can update and amend your key contact information directly.
 
We respect the rights you may have under applicable law to request access to your personal data and where applicable, to request to receive that information in a commonly used electronic format (or ask for this information to be provided in that format to a third party where feasible). You may also have the right under applicable law to request the correction or erasure of your personal data, to seek to object to the further processing under certain circumstances of your information or to request that the processing of specific information about you is restricted while we verify or investigate your concerns about this information.
 
In addition, if you believe that we have not responded to your privacy-related inquiry or your inquiry has not been satisfactorily addressed, please contact Sega of America’s Data Protection Officer (contact details below) or the ESRB at https://www.esrb.org/privacy/contact.

For users in the EEA/UK - If you remain unhappy with a response you receive, you can also refer the matter to your data protection supervisory authority (see http://ec.europa.eu/justice/data-protection/bodies/authorities/index_en.htm).
 
6. Children’s information
 

If SEGA learns that personal data of underage users has been collected, other than for support of our internal operations, SEGA will take reasonable steps to remove such information. If you believe that we may have unintentionally collected personal data about your child who is underage, you may contact us using the details provided below.
 
7. California Residents
 
Your California Privacy Rights
California Civil Code Section 1798.83 (“Shine the Light”) permits our customers who are California residents to request, once per calendar year, the following information from us: 
 
(i) a list of the kinds of personal information that we have disclosed to third parties for direct marketing purposes during the preceding calendar year; and
(ii) the names and addresses of all of the third parties that received personal information from us for direct marketing purposes during the preceding calendar year.
For inquiries regarding our disclosure policy, please contact us as described below. Requests must include “California Privacy Rights Request” in the first line of the description and include your name, street address, city, state, and ZIP code.
 
California Business and Professions Code Section 22581 (“California Privacy Rights for Minor Users”) permits you, if you are a California resident under the age of 18, to view, correct or remove information provided by you or publicly posted by you. For inquiries regarding our disclosure policy, please contact us as described below in Section 10 “Your questions and how to contact us”. Requests must include “California Privacy Rights Request” in the first line of the description and include your name, street address, city, state, and ZIP code. Any enquiries from underage users will be deleted upon completion.
 
Your Rights under the California Consumer Privacy Act (the “CCPA”)
Our customers who are California residents have the following rights under the CCPA:
 

• The right to request the deletion of their personal information;
• With respect to the collection of personal information, the right to request, not more than twice in any twelve (12) month period, the following: (i) categories of personal information we have collected about that consumer; (ii) categories of sources from which the personal information is collected; (iii) business or commercial purpose for collecting or selling personal information; (iv) categories of third parties with whom we share personal information; and (v) specific pieces of personal information we have collected about you;
• With respect to the sale and/or disclosure of personal information, the right to request, not more than twice in any twelve (12) month period, the following: (i) categories of personal information that we have  collected about the consumer; (ii) categories of personal information that we have sold about the consumer and the categories of third parties to whom the personal information was sold, by category or categories of personal information for each third party to whom the personal information was sold; and (iii) categories of personal information that we have disclosed about the consumer for a business purpose;
• The right to opt-out of the sale of personal information; and
• The right to not be discriminated against for exercising any of the above described rights.

 
Do Not Sell My Personal Information
To exercise any of your rights under the CCPA, please contact us via email, web query or phone (details below) and be ready to provide your name, address, and email. We may ask for other information in order to confirm your identity.  Any information we receive from you in order to confirm your identity will solely be used for such verification purposes.
 
You may also designate an authorized agent to make a request on your behalf. If you choose to designate an agent, please be sure the agent can
(i) provide written permission from you for the agent to make the request on your behalf, and
(ii) provide proof of his or her own identity.
 
Further Disclosures Under the CCPA
During the past twelve (12) months, we have collected the following categories of personal information from the following sources, for the following purposes, and have shared them with the following third party service providers:
 
Personal Identifiers & contact information: Information you give us when you sign up to access our Products, or other information you choose to give us. Our purposes for collecting this information are:
 

• To create your profile and so you can access our Products;
• To provide Products you request;
• To identify you when you sign-in;
• To give you access to your user preferences;
• To contact you for your views on our Products;
• To allow participation in special events or contests (if specifically approved by you);
• To notify you of changes or updates to our Products; and
• For marketing purposes, based on your communication preferences.

Commercial Information: Information provided by you and/or third party stores. Our purposes for collecting this information are:
 

• To verify your purchase of our Products and process any refunds
• To reply to any queries and questions and to resolve billing-related problems
• To carry out analysis and research to develop our Products
• To protect you and the Products by seeking to detect and prevent fraud or other acts in breach of our terms of service or policies relevant to the Products

Technical and Device Information/Internet Activity: Information from your mobile or computer device when you use our Products. Our purposes for collecting this information are:
 

• To provide you with an optimal experience
• To understand how you interact with our Products
• To provide Products you request
• To measure and analyze the use and effectiveness of our Products
• To understand which of your devices are using our Products
• To provide safe and fair gaming environments
• To track consents for use of personal information related to our Products
• To serve advertisements within the Products
• To customize and optimize the targeting of advertising both on our Products and across third party websites, apps and products
• To operate and improve our Products
• To fix errors

Feedback: Your questions, suggestions or views on the Products. Our purposes for collecting this information are:
 

• To reply to your questions or queries
• To record comments and information which you provide on our gaming forums
• To conduct analysis and research to improve and develop the Products

Third Party Information: Information about your use of our Products that is shared with third party platforms and services connected with our Products. Our purposes for collecting this information are:
 

• To enable us to provide tailored offers to you
• To facilitate sharing on social networks
• To facilitate your gameplay

The Categories of Parties With Whom We Share Personal Information
 

• Affiliates within the wider SEGA group
• Third party service providers who carry out various activities and services in support of or for the benefit of our Products
• Advertising partners for the service of advertisements within our Products
• Marketing partners for marketing or promotions such as Mailchimp, based on your communication preferences

We do not “sell” consumer data as most people would understand the term “sell”.  However, the CCPA defines the “sale” of information broadly to include activities we believe most people would understand as “information sharing”.   For example, the CCPA defines “sell,” “selling,” “sale,” or “sold,” as selling, renting, releasing, disclosing, disseminating, making available, transferring, or otherwise communicating orally, in writing, or by electronic or other means, a consumer’s personal information by the business to another business or a third party for monetary or other valuable consideration.  The term “other valuable consideration” is not defined in the CCPA.  Notwithstanding that, we do not believe we “sell” consumer data as the term “sell” is defined under the CCPA.  However, we do share consumer data with our affiliates, third party service providers, advertising partners and marketing partners as explained above in this Further Disclosures Under the CCPA section.   To the extent those activities may constitute a “sale”, we have shared such data with such parties the past twelve (12) months and anticipate continuing to share such data with the same parties in the next twelve (12) months.  If our data sharing practices change, we will update this policy to reflect that change.
 
 
8. Nevada Residents
 
Our customers who are Nevada residents have the right at any time to request that we do not sell the following information regarding them to third parties:
(1) the customer’s first and last name;
(2) the customer’s physical address which includes the name of a street and the name of a city or town;
(3) the customer’s e-mail address;
(4) the customer’s  telephone number;
(5) the customer’s social security number;
(6) the customer’s identifier that allows a specific person to be contacted; or
(7) any other information concerning a customer collected from the customer through our Internet website or online service and maintained in combination with an identifier in a form that makes the information personally identifiable. 

To exercise your right to opt out of the sale of Covered Information under Nevada law, please contact us (contact details below) and be ready to provide your name, address, and email. We may ask for other information in order to confirm your identity.  Any information we receive from you in order to confirm your identity will solely be used for such verification purposes.
 
9. Mobile Applications
 
Certain Mobile Products are currently supported by third party advertising partners that serve advertisements (“Third Party Advertisers”), including behavioural, location or interest based advertising (“Interest Based Advertising”) within our Products. These Third Party Advertisers use technology to serve the advertisements and link to them directly into our Products.  They may automatically receive your device ID, IP address or geo-location data (limited to country/region) when this happens.
 
Please see the list of Third Party Advertisers and Partners in Appendix A used within certain Products, and their respective privacy policies for information regarding their privacy practices.
 
Your mobile device may provide you with the ability to limit this functionality.
 
iOS (versions 10-13) – On your iOS device (iPhone or iPad), open “Settings > Privacy > Advertising” and turn on “Limit Ad Tracking” to opt-out of interest based ads. Please see additional information from Apple here: https://support.apple.com/en-us/HT202074
 
iOS (version 14.5+) – On your iOS device (iPhone or iPad) open “Settings > Privacy > Tracking” and turn off “Allow Apps to Request to Track”
 
Android – Open the Settings app on your Android phone, tap Ads and enable “Opt out of interest based ads”.
 
Please note that if you opt out of certain Interest Based Advertising, you may continue to receive contextual ads based on other non-personal information, such as ads related to the content of the Product you are using.
 
Opt-Out for Location Data
 
Certain Third Party Advertisers in Products may collect (with your permission) precise location data, or street-level location information, about you (“Precise Location Data”). Your mobile device may allow you to opt out of the collection of Precise Location Data by the Third Party Advertiser in the Product, as further described below. Please note that your mobile device will not share location information without your permission.
 
iOS – In order to disable the collection of Precise Location Data on iOS, you may turn Location Services off for the applicable Product via the menu “Settings > Privacy > Location Services”. Then select the applicable Product and set the “Share My Location” status to “Never”. Please see additional information from Apple here: https://support.apple.com/en-us/HT203033.

 
Android (6.0 / Marshmallow and higher) - In order to disable the collection of Precise Location Data on Android, you may turn Location off for the applicable Product via the menu “Settings > Apps > [applicable Product] > Permissions > Location”.  Then turn off the “Location” button.
 
10. Your questions and how to contact us
 
If you have any questions or comments about this policy or our practices you can contact us:
By email at:                  help@segaamerica.com
By telephone on:          +1 (833) 390-0939
By writing to us at:
Sega of America, Inc.
6400 Oak Canyon, Suite #100
Irvine, California 92618
 
If you are located in the United Kingdom (UK) you can contact Sega of America’s UK representative at:
ATTN: SOA DPO
SEGA Europe Ltd
27 Great West Road
Brentford, Middlesex, TW8 9BW
 
You can also contact our data protection officer at dataprivacy@segaamerica.com.