Last Updated: February 27, 2020

This Privacy Policy explains how information about you is collected, used and disclosed by BANDAI NAMCO Entertainment Inc., (“BNEI”, “us”, “we” or “our”) when you use our games and related online services that contain this policy (collectively, the “Game”). BNEI is the data controller of your personal information for purposes of the EU General Data Protection Regulation.

We may change this Privacy Policy from time to time. If we make changes, we will notify you by revising the date at the top of the Privacy Policy and, in some cases, we may provide you with additional notice (such as by adding a statement to the homepage of our Game or sending you a notification). If you do not agree to the changes, please do not use our Game or otherwise provide us with your personal information. We encourage you to review the Privacy Policy whenever you access the Game to stay informed about our information practices and the ways you can help protect your privacy.

I. Collection of Information

Information We Collect Automatically When You Use the Game

When you access or use any online features associated with our Game, we automatically collect information about you, including:

• • Usage Information: We collect information about your use of the Game, including gaming account ID, levels completed, game scores, time spent playing the Game, and other gameplay information.
• • Log Information: We log information about your use of our Games, including your access times, time spent playing, and your IP address.
• • Hardware Information: We collect information about the computer or device you use to access our Game, including the hardware model, operating system and version, browser network information, MAC address, IP address and other unique device identifiers made available by the operating system of your hardware.

Information You Provide to Us

We collect information you provide directly to us. For example, we collect information when you create an account, interact with other users, request customer support, sign up to receive newsletters, participate in surveys or otherwise communicate with us. The types of information we may collect include your username, password, email address and any other information you choose to provide.

Information We Collect From Other Sources

We may also obtain information from other sources as far as it is necessary to perform our Game, and combine that with information we collect through our Game. For instance, we may obtain information regarding your account from your gaming platform, or may collect game ranking and achievement status from your console game center application. In all other cases we will ask you to authorize us to collect, store, and use personal information from third parties.

II. Use of Information

We only collect, store and use your information if you have consented to it, or to the extent that it is necessary (i) for the performance of your agreement with us; (ii) to comply with our legal obligations; or (iii) for the purpose of our legitimate interests, including operating, evaluating and improving our global business. We have carefully balanced our legitimate business interests against your data protection rights. Please contact us using the contact details provided below if you have questions on this balancing of interests.
We (or a third party data processor on our behalf) may collect, store and use information about you for the following purposes for the periods necessary to achieve such purposes:

• • Provide, maintain and improve our Game;
• • Provide and deliver the products and services you request, process transactions and send you related information;
• • Register you for an account on our Game and assist in the management of your account;
• • Respond to your comments, questions and requests and provide customer service;
• • Send you technical notices, updates, security alerts and support and administrative messages;
• • Communicate with you about products, services, offers, promotions, rewards, and events offered by BNEI and others, and provide news, information and other marketing materials that we think will be of interest to you;
• • Monitor and analyze trends, usage and activities in connection with our Game;
• • Link or combine with information we get from others to help understand your needs and provide you with better service;
• • Detect, investigate and/or prevent fraudulent, unauthorized or illegal activity;
• • For any other purpose required or authorized for us to comply with our legal and regulatory obligations; and
• • For any other purpose for which you provided the information.

III. Sharing of Information

We do not share, transfer or otherwise exchange your personal information with third parties, unless required for the provision of our products or services, otherwise in accordance with this Privacy Policy, as permitted by law, or if you have given us express consent. We do not sell your personal information to third parties. In compliance with the aforementioned, we may share information about you as follows or as otherwise described in this Privacy Policy:

• • With other users if you choose to participate in the interactive areas of our Game, such as chat or multiplayer features (the use of personally identifiable data (such as your full name) as a username in our services is strictly prohibited);
• • With our employees, affiliates, related companies, vendors, consultants and other third party service providers who need access to such information to carry out work on our behalf (including, for example, developers, website hosting services, or information storage and processing service providers);
• • In response to legal process or a request for information if disclosure is in accordance with, or as otherwise required by, any applicable law, rule, or regulation (including, for example government or regulatory bodies, law enforcement, or courts of law);
• • If we have reasonable grounds to believe your actions are inconsistent with our user agreements or policies, or to protect the rights, property and safety of BNEI, our users or others;
• • In connection with any merger, sale of company assets, financing or acquisition of all or a portion of our business to another company; and
• • With your consent or at your direction.

IV. Game Analytics

Some of our Games will, with your prior consent, combine game play and analytic information with information collected from other BANDAI NAMCO Entertainment games, games from our group companies, and other third party sources. We will use that information to analyze game and monetization trends, create profiles of categories of players, create new games and services, and perform other analytics. You can opt-out of this use through the options menu in the Game.

V. Security

We take reasonable technical and organizational measures to help protect information about you from loss, theft, misuse and unauthorized access, disclosure, alteration and destruction. However, no transmission over the internet can ever be guaranteed secure so we cannot guarantee the security of any personal information that you transfer over the internet to us.

VI. Storing and deleting data

Personal information collected through the Game is being stored and deleted in compliance with privacy requirements. All data will be de-identified or deleted if no longer required for the purposes mentioned above, unless further retention is required by law.

VII. International Transfers

Personal information that we collect from you is usually transferred, stored and processed in Japan. Please be aware that we may transfer your personal information to locations outside of your country which may not offer the same level of data protection as your country’s laws. However, our collection, storage and use of your personal information will continue to be governed by this Privacy Policy, and where we do disclose your personal information to third parties located overseas, we take such steps as are reasonable in the circumstances to ensure it is used in accordance with this Privacy Policy.

VIII. Third Party Sites

Our Games may contain links to other websites or services operated by third parties. Please note that this Privacy Policy applies only to our Game and we cannot be responsible for personal information that third parties may collect, store and use through their website. You should always read the privacy policy of each website you visit carefully.

IX. Data Protection Rights

You, and your legal guardian if you are a minor, have certain data protection rights under applicable law. Your rights under applicable law may include:

• • Access to the personal information we process about you as well as the right to data portability.
• • The right to have personal information corrected or erased.
• • The right to restrict the processing of your personal information.
• • The right to withdraw your consent at any time for consent we have obtained from you, although this will not affect the lawfulness of the processing prior to the withdrawal.
• • You also have the right to object, at any time, to the processing of your personal information which is based on BNEI’s legitimate interests.
• • Where we process your personal information for direct marketing purposes, you have the right to object at any time to such processing, including for profiling purposes to the extent that it is related to direct marketing. If you object to processing for direct marketing purposes, we will no longer process your personal information for such purposes. In that case we may still send you transactional or relationship messages, but only about our ongoing business relations.

If you have such a request, you may address your requests to ppolicy@bandainamcoent.co.jp.
We do not provide different levels of service if you exercise these rights. However, if you request we delete or cease collecting information which is necessary to ensure adequate functioning of the Services, you may not be able to use all or some parts of our Services.

X. Contact

If you have any questions about this Privacy Policy or our practices, please contact us at:
BANDAI NAMCO Entertainment Inc.
Attn: Contact for Personal Information Matter
5-37-8 Shiba
Minato-ku, Tokyo 108-0014
Japan
+81-3-6744-6112 (phone)


If you are located in the European Union, you can also contact us at:
BANDAI NAMCO Entertainment Europe S.A.S.
49, 51 Rue des Docks CS
90618 69258 LYON Cedex 09 FRANCE