BANDAI NAMCO ENTERTAINMENT INC.

PRIVACY POLICY

Last Updated: December 1, 2018

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, sell, 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 unless you have given
us express
consent. 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.
If you refuse to provide your personal information or request we delete or cease
collecting
your personal information, you may not be able to use all or some parts of our
Game.
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)
ppolicy@bandainamcoent.co.jp
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
privacy@bandainamcoent.eu