SEGA PRIVACY POLICY

Introduction

SEGA(“ SEGA ”, “we”, “us” or “our”) is committed

to protecting the privacy and security of your personal information.

SEGA collects different types of information from you

when you use our online and downloadable products

and services ("Products").

This Privacy Policy explains how we collect,

use and protect your personal information

when you use our Products.

By using our Products you acknowledge that

you have read and understood

the terms of this Privacy Policy,

including how we use your personal information.

SEGA is the data controller of your personal information

for purposes of the EU General Data

Protection Regulation (“GDPR”; EU2016/679).

See 'Your questions and how to contact us' section of

this Privacy Policy for more details.

    

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 the Products.

The date of the current SEGA Privacy Policy is

the Effective Date set out above.

We want you to enjoy using our Products and urge you to

follow common sense whenever disclosing

personal information – in our Products or elsewhere.

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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 continuing to scroll down:

  1. Information we collect and receive

We collect personal information 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 SEGA Products

(b) Billing information: provided by you and/or third party stores

(c) Technical and device information: information from your console

  or computer device when you use our Products

(d) Feedback: your questions, suggestions or views on the 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

  1. 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 provide Products you request;

(iii) to identify you when you sign-in;

(iv)  to give you access to your user preferences;

(v)  to contact you for your views on our Products;

(vi)  to allow participation in special events or contests

  (if specifically approved by you);

(vii) to notify you of changes or updates to our Products; and

(viii)     for marketing purposes, based on your

  communication preferences.

(b)  Billing information:

(i)  to verify your purchase of our Products and process

any refunds,if it is requested

by the game platform providers;

(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 the Products by seeking to detect

  and prevent fraud or other acts in breach of our

  user agreements, terms of service or policies

  relevant to the Products.

(c)  Technical and device information:

(i)  to provide you with an optimal experience;

(i)  to understand how you interact with our Products

(iii) to provide Products you request; 

(iv)  to measure and analyze 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 measure and analyze the use and effectiveness

  of our Products;

(viii)     to serve advertisements within the Products;

(ix)  to customize and optimize the targeting of advertising

  both on our Products and across third party websites,

  apps and products;

(x)  to operate and improve our Products; and

(xi)  to fix errors.

(d)  Feedback:

(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 the 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.

  1. 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 information with:

(a)  SEGA companies within the wider SEGA group.

(b)  Third party service providers who need access to such

  information to carry out work on our behalf

  (e.g. website hosting services, information storage).

(c)  Platform operators and other partners who carry out various

  activities and services to support our Products.

(d)  Advertising partners for the service of advertisements

  within our Products.

(e)  Marketing partners for marketing or promotions,

  based on your communication preferences.

(f)  New owners or re-organized entities and

  their advisors in the event of a business restructure, sale,

  purchase or joint venture affecting our business.

(g)  Where we are under a duty,

  are authorized by law or for law enforcement purposes.

Personal information that we collect from you is usually transferred,

stored and processed in the US. Personal information

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 the Products.

  1. Security and data retention

Your privacy is important to us and we take reasonable

technical and organizational measures to protect your information

from unauthorized access and against unlawful processing,

accidental loss, destruction and damage.

Your personal information 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,

our terms with you and in accordance with applicable laws.

  1. Your choices and rights

You have options and choices over how

we use your personal information.

You may be required to register or sign in to use or access

some of our Products, and may need to

provide personal information

to create a user profile which is associated

with your use of our Products.

Where you are required to sign in to use or access our Products,

you can also manage and amend the personal information

that you provide to us. In addition you can also

contact us using the details below.

Sega of America, Inc.

6400 Oak Canyon, Suite 100, Irvine, CA 92618, U.S.A

Sales and distribution of consumer

https://support.pso2.com

If you sign up to our marketing communications,

you will be asked to confirm your

communication preferences and

given the opportunity to unsubscribe at any time.

You can contact us directly with requests to

correct, erase, restrict,

object to, or move your personal information.

If you do not want us to process and/or

access your personal information,

you may be unable to use some of our Products.

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 information or non-personally identifiable information

from users under 13 years of age or

other applicable age of consent,

other than as permitted by law in support of our internal

operations and/or for our legitimate interests.

  1. Your questions and how to contact us

If you have any questions or comments about

this Privacy Policy you can contact us.

Sega of America, Inc.

6400 Oak Canyon, Suite 100, Irvine, CA 92618, U.S.A

Sales and distribution of consumer

https://support.pso2.com

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More information

  1. Information we collect

We collect personal information 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

we collect information about you including your name,

contact details, age, gender, personal preferences and additional

information that you chose to provide.

We may also collect your contact information so that you can

sign-up to receive SEGA's marketing communications.

As part of any required sign in to use our Products,

we will verify the information that you use to log in.

  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.

We do not control (nor act as the controller of) the information

that is sent from your device to third parties,

including game platforms and analytics companies which receive

information in the normal course of your online activities.

(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 in order to verify

your purchases, process any refund payments,

contact you to resolve any product issues,

and/or deliver Products to you. We may collect this information

from you and/or third party stores that

have been authorized to sell our Products.

(c)  Technical and device information

We collect information from your device and activity

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 on our Products,

such as forums and chat functionality, may be stored,

copied or used by SEGA, the public, or third-party companies.

By accessing our Products, we may collect

technical information from your console 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,

Internet Protocol address, your browser type,

browser language preferences and when,

how often and how long you interact with our Products,

websites and services.

We also use software to enable us to provide

safe and fair gaming environments for all users

of our Products and when you log in to one of our Products,

or make purchases.

We, and or our third party suppliers

may use cookies and similar technologies,

or collect data about your device(s) to create a device

fingerprint of the components of your specific device(s) and/or

build an individual profile of you.

         

(d)  Feedback

We will collect personal information from

the messages and reviews

you post on our social forums,

and when you contact us, for example with a question,

problem or comment. If you contact our

customer services team by email or post,

we will keep copies of your correspondence

with us for as long as necessary to deal with your query.

(e)  Third party information

We collect information obtained from your use of our Products

from third parties to provide you with an optimal experience,

to facilitate use of the Products as advertised,

to enable you to play our Products on various platforms and

to optimize our Products.

  1. How we use the information we collect

We use the personal information we collect

for the following purposes:

(a)  Registration information

Your registration information enables us to provide

you with access to the Products and to supply

the Products under the agreements

we have with you and the relevant terms of service.

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. 

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 post, email, telephone,

console or in-app messaging about our

other products and services.

If you no longer want us to use your 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.

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.

(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 analyze

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 the Products.

(c)  Technical and device information

We analyze 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-optimizing software updates for our Products.

We use anonymous data in order to analyze 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 personalized content,

helps us understand the features of our Products that appeal to

you and allows us to manage advertising, amongst other things.

When you interact or visit our websites,

we may automatically collect information about you

such as the type of internet browser or console device you use,

any website from which you have come

to any of the SEGA Products and

your IP address (the quasi-unique address which identifies

your device on the internet) and your operating system,

which are automatically recognized by our web server.

We use log files to monitor traffic on our Products,

resolve technical problems and to detect and prevent fraud.

We use these technologies 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 and for and in our Products. In some cases,

including 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 videogames, 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.

We also use this information to deliver you personalized content,

help us understand the features of our Products that appeal to

you and allows us to manage advertising.

(d)  Feedback

We use your feedback to reply to your questions or queries,

to provide customer support and resolve problems relating to

any of our Products under the agreements that

we have with you.

We will also publish reviews that you submit

to us for this purpose

about the Products and will conduct analysis of feedback

for the purpose of improving and developing the Products.

(e)  Third party information

We use information obtained from third parties to provide you

with an optimal experience,

to facilitate use of the Products as advertised and to

enable you to play our Products on various platforms.

When we share information

In delivering the Products to you,

we may share your personal information with:

  • Companies within the SEGA group

     (which means SEGA companies 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 parties in order to undertake various activities or services

     on our behalf in supporting the 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.

  • 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 organizations 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.

We do not control information which is sent from your browser

to third parties, and may not control certain information

which is sent from our Products to third parties,

including game platforms and analytics companies

that receive information in the normal

course of your online activities.

Personal information may be transferred to other

countries where SEGA

or our service providers maintain operations.

These countries may not have equivalent data protection

laws to the country from where you access the 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 information

we will seek to take account of any applicable legal

obligations relevant to personal information transfers.

In the case of transfers of personal information subject to

the law of the European Union to a country

which is not part of the European Economic Area,

we will, in the absence of an EC adequacy decision relevant

to the destination country, seek to rely on appropriate safeguards

such as a valid Privacy Shield certification

(in the case of a data transfer to a Privacy Shield certified US

recipient - Please visit https://www.privacyshield.gov/welcome for

more information) or enter into appropriate EC approved standard

contractual clauses relevant to

personal data transfers between data

controllers or between a data controller and a data processor,

(please visit https://ec.europa.eu/justice/data-protection/

international-transfers/transfer/index_en.htm for more information).

  1. Security and data retention

We place great importance on the steps we take,

including physical,

technical and organizational measures, to protect your information

from unauthorized access and against unlawful processing,

accidental loss, destruction and damage.

Where you have chosen a password which allows you to access

any of the 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 unauthorized transactions

entered into using your username,

personal information and/or password.

Your personal information 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, the relevant terms of service,

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 information 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.

  1. 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 the 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 information 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 information,

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.

We do not verify the correctness of your personal information.

If you remain unhappy with a response you receive,

you can also refer the matter to your data protection supervisory

authority if your personal information is subject to

the law of the European Union

(please visit https://ec.europa.eu/justice/data-protection/

bodies/authorities/index_en.htm for more information).

  1. Children’s information

If SEGA learns that personal information of users

under the age of 13 or other applicable age of

consent has been collected,

other than for support of the internal operations and/or for

our legitimate interests, SEGA will take reasonable steps to

remove such information. We may collect

non-personally identifiable

information from children, such as country settings and

language settings to ensure compliance

with the applicable law for

the specified country. If you believe that

we may have unintentionally collected personal information

about your child, you may contact us using

the details provided below.

  1. Your questions and how to contact us

If you have any questions or comments about

this policy or our practices you can contact us:

Sega of America, Inc.

6400 Oak Canyon, Suite 100, Irvine, CA 92618, U.S.A

Sales and distribution of consumer

https://support.pso2.com