SEGA CORPORATION PRIVACY POLICY
Introduction
SEGA CORPORATION, its subsidiaries and affiliates (together "SEGA" or "SEGA Group", individually a "SEGA Entity") are committed to protecting the privacy and security of your personal information. The term "personal information" used herein also includes "personal data" and equivalent terms, as such terms are defined under applicable laws. SEGA collects different types of information from you, including personal information, when you apply to the "Ryu ga Gotoku Studio Official YouTube Channel Membership Game Appearance Opportunity" (the "Campaign").
This Privacy Policy explains how we collect, use and protect your personal information when you interact with us. SEGA is responsible for collecting and using your personal information. See the "Your questions and how to contact us" section of this Privacy Policy for more details.
By applying to the Campaign, you acknowledge that you have read and understood the terms of this Privacy Policy, including how we use your personal information. We reserve the right to update this Privacy Policy from time to time by changing it as it applies to your interaction with us. We want you to enjoy the Campaign and urge you to follow common sense whenever disclosing personal information.
1. INFORMATION WE COLLECT AND RECEIVE
We collect personal information about you. We collect:
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(a) Registration information: |
Information provided when you apply to the Campaign (name, address, date of birth, age, gender, nickname, etc.) |
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(b) Technical and device information: |
Information from your mobile, computer, or console devices when you interact with us |
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(c) Feedback / surveys / user research and product testing: |
Your questions, suggestions or views on the Campaign |
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(d) 3D facial model information - special category data |
Your facial image, height, other physical characteristics, and 3D facial model |
2. OUR USE OF COLLECTED INFORMATION
We may use your information for the following purposes:
- (i) Managing applicants and choosing participants in the Campaign
- (ii) Developing a game character based on your likeness
- (iii) Adding your name to the credits of the game in which said character appears
- (iv) Management of consent forms, photographed models and portraits
- (v) Identity verification
Non-special category data of users who apply to the Campaign is processed for our legitimate business interests. In addition, for those who are chosen to take part in the facial scanning for the Campaign upon execution of agreement therefor, the non-special category data of such data subjects shall be processed to perform SEGA's duties under the agreement between such individuals and SEGA.
We process 3D facial model information which may constitute biometric data only based on explicit consent from the individual, or their parent or legal guardian in the case of an eligible underage user.
3. HOW WE DISCLOSE INFORMATION
We may disclose the information we collect about you to contractors entrusted with tasks necessary for implementing the Campaign (subject to legally required security, contractual and transfer safeguards). These are some of the partners we may disclose your personal information to:
(a) SEGA companies within the wider SEGA Group;
(b) Third parties we collaborate with in connection with the Campaign;
(c) Others at your direction and with your consent;
(d) New or potentially new owners or re-organized entities and their advisors in the event of a business restructure, transfer, merger, dissolution sale, purchase, joint venture, or similar event involving our business (including in contemplation of such transactions); and
(e) Law enforcement agencies/authorities or others, when we are under a duty or are authorized by law for law enforcement purposes or to enforce relevant terms of service and any other agreement or to protect our rights or the rights of third parties.
4.SECURITY AND DATA RETENTION
Your privacy is important to us and we place great importance on the steps we take, including physical, technical and organizational measures, to protect your personal information from unauthorized access and against unlawful processing, accidental loss, destruction and damage. However, no method of transmission over the internet, and no means of electronic or physical storage, is absolutely secure. We cannot guarantee the security of your personal information transmission and that any such transmission is at your own risk.
We will retain your personal information for the duration of the Campaign and may retain it for a period after this time as necessary and relevant to our legitimate operations (e.g., to resolve disputes), 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 fulfil transactions you have requested, enforce any obligations in our agreements or to identify, issue or resolve legal proceedings or disputes, fraud prevention, and related security purposes. We retain information only as long as considered necessary by taking into account the amount, nature and sensitivity of the information, the potential risk of harm from unauthorized use or disclosure of the information, the purposes for which we process the information, applicable legal requirements, and our general business operations.
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. We may retain cached or archived copies of your personal information.
5. YOUR CHOICES AND RIGHTS
If you wish to amend the personal information that you use to apply to the Campaign; object to our processing of your personal information; or would like us to correct, erase, restrict, or move your personal information, you can contact us using the details below. Please note that if you do not want us to process and/or access your personal information, you may be unable to participate in the Campaign.
RIGHTS REGARDING YOUR INFORMATION
We provide you with tools to access and update specific information relating to your application to the Campaign at any time.
Depending on your jurisdiction, you may have the right to make certain requests regarding your personal information, as listed below.
You have the right to ask us to:
- Inform you about the categories of personal information we collect or disclose about you; the categories of sources of such information; the business or commercial purpose for collecting your personal information; and the categories of third parties with whom we disclose personal information.
- Provide you access to and/or a copy of certain personal information we hold about you.
- Correct or update personal information we hold about you.
- Delete certain personal information we have about you.
- Provide you with information about the financial incentives that we offer to you, if any.
- Opt you out of the processing of your personal information for purposes of profiling in furtherance of decisions that produce legal or similarly significant effects, if applicable.
You may also have the right to opt out of "sales" of your personal information and "sharing/use of your personal information for targeted advertising" as described below.
As provided in applicable laws, you also have the right to not be discriminated against for exercising your rights. Please note that certain information may be exempt from such requests under applicable laws. For example, we need to retain certain information in order to provide our services to you. We also need to take reasonable steps to verify your identity before responding to a request, which may include, at a minimum (depending on the sensitivity of the information you are requesting and the type of request you are making), verifying your name and email address. Depending on your jurisdiction, you may be permitted to designate an authorized agent to submit certain requests on your behalf. In order for an authorized agent to be verified, such individual may be requested to provide proof of your signed, written and informed permission to make such requests or a power of attorney. We may also follow up with you to verify your identity before processing the authorized agent's request. If you would like further information regarding your legal rights or would like to exercise any of them, please email us at dataprivacy@sega.com.
Depending on applicable laws, you may have the right to appeal our decision to deny your request, if applicable. To exercise such an appeal right, please contact us via the communication method(s) as noted in our decision.
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 us using the contact details below or at dataprivacy@sega.com.
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
Protecting the privacy of young children is especially important to SEGA. For that reason, SEGA does not knowingly collect, maintain, sell or share personal information or non-personally identifiable information from underage users other than as permitted by law or with the consent of a parent or legal guardian. In this Privacy Policy, any reference to underage users refers to those under the age of consent to the processing of personal information in their country of residence.
If SEGA learns that personal information of underage users has been collected unlawfully, SEGA will take reasonable steps to remove such information. If you believe that we may have unintentionally collected personal information about your child who is underage, you may contact us using the details provided below.
7. CALIFORNIA PRIVACY NOTICE
This section supplements our Privacy Policy with additional information for California residents about our personal information collection and use practices as required by the California Consumer Privacy Act 2018, as amended by the California Privacy Rights Act of 2020 (the "CCPA"), Privacy Rights for California Minors in a Digital World, and the California Shine the Light, and provides information about California residents' rights under those laws. In this section, the terms "personal information" and "sensitive personal information" have the meaning set forth in the CCPA.
The following chart provides information about our practices in the 12 months leading up to the effective date of this Privacy Policy in relation to the categories of personal information that we have collected from California residents generally, the purposes for which we use the information, and the categories of third parties to whom we disclose the information for business and operational purposes.
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Categories of personal information collected (see "The Information We Collect" section above for additional information) |
Purpose of use |
Categories of third parties to whom we disclose the personal information for business and operational purposes (See "How We Disclose the Information We Collect" section above for additional information) |
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Identifiers |
· Process application to the Campaign · Verify and authenticate your information, account, and interactions with us · Communicate with you · Personalize your experience |
· Affiliates · Entities for legal and security purposes · Others with your consent |
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Demographic information |
· Process application to the Campaign · Verify and authenticate your information, account, and interactions with us · Personalize your experience |
· Affiliates · Entities for legal and security purposes · Others with your consent We may inform third parties if we know that you are under the age of consent (see "Children's Information" section above). |
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Customer service information |
· Process application to the Campaign · Communicate with you · Improve the Products |
· Affiliates · Entities for legal and security purposes · Others with your consent |
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Transactional information |
· Process application to the Campaign · Communicate with you · Provide customer service · Improve the Products |
· Affiliates · Entities for legal and security purposes · Others with your consent |
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Internet network and device activity data |
· Provide customer service · Personalize your experience · Improve the Products |
· Affiliates · Entities for legal and security purposes · Others with your consent |
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Geo-location information |
· Process application to the Campaign · Provide customer service · Personalize your experience · Improve the Products |
· Affiliates · Entities for legal and security purposes · Others with your consent |
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3D facial model information such as facial image, height, other physical characteristics, and 3D facial model |
· Generate 3D models of participants in the Campaign and utilizing them in the development of the game |
· Affiliates · Entities for legal and security purposes · Others with your consent |
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Other information |
· Purposes of use will depend on the additional information you provide |
· Disclosure will depend on the additional information you provide |
OTHER CALIFORNIA 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 by emailing dataprivacy@sega.com. Requests must include "Shine the Light 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 by emailing dataprivacy@sega.com. Requests must include "California Privacy Rights for Minor Users Request" in the first line of the description and include your name, street address, city, state, and ZIP code.
8. NEVADA RESIDENTS
Under Nevada law, certain Nevada residents may opt out of the "sale" of "covered information" (as such term is defined under Nevada law). We do not engage in such activity as of the effective date of this Privacy Policy.
9. INTERNATIONAL USERS
Personal information may, in accordance with applicable laws, be transferred to countries other than your country of residence where SEGA or trusted business partners maintain operations, including the United States. 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 information to that in the EU, through its domestic law or its international commitments. Such third parties may be engaged in, among other things, the implementation of the Campaign. By providing us with your personal information, you acknowledge any such transfer, storage, or use by such third parties.
Where SEGA transfers personal information it will seek to take account of any applicable legal obligations relevant to personal information transfers. In the case of transfers of personal information out of the European Economic Area, it will, in the absence of an EC adequacy decision for the destination country, seek to rely on appropriate safeguards such as the EC approved standard contractual clauses relevant to personal information transfers between data controllers or between a data controller and a data processor (see https://commission.europa.eu/law/law-topic/data-protection/international-dimension-data-protection/standard-contractual-clauses-scc_en ).
10. CHANGES TO THIS PRIVACY POLICY
We may update this Privacy Policy from time to time in our sole discretion. You can know if the Privacy Policy has changed since the last time you reviewed it by checking the "Last Updated" date at the top of this page. We encourage you to look for updates and changes to this Privacy Policy periodically. If we make a material change to this Privacy Policy, we will endeavor to notify you through the Products, by email, and/or by other legally permissible communication as required by applicable laws. Your continued use of the Products after any changes to this Privacy Policy are in effect constitutes your acceptance of revisions to the Privacy Policy.
11. YOUR QUESTIONS AND HOW TO CONTACT US
If you have any questions or comments about this Privacy Policy or our practices, you can contact us:
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By email at: |
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By telephone at: |
+1 (888) 695-5073 |
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By writing to us at: |
SEGA Corporation |
UK and EU Representative Contact Information:
UK: For the ICO and UK Residents
We have appointed Enobyte GmbH as our UK representative under Article 27 of the UK GDPR. If you have any questions or concerns regarding data protection and data processing, you may contact our representative below:
Enobyte GmbH
c/o Regus Bloomsbury HQ
4/4a Bloomsbury Square, London
Greater London, WC1A 2RP
United Kingdom
Web: https://enobyte.com/
Email: ukrep-sega@enobyte.com
EU: For EU Supervisory Authorities and EU Residents
We have appointed Enobyte GmbH in Germany as our EU representative under Article 27 of the GDPR. If you have any questions or concerns regarding data protection and data processing, you may contact our representative below:
Enobyte GmbH
Augustenstr. 49
D-80333 Munich
Web: https://enobyte.com/
Email: eurep-sega@enobyte.com
You may also contact SEGA directly using the contacting details listed for SEGA above.