Last updated on June 23, 2023 

Sega of America, Inc. collects information about you when you use our games for Apple Arcade ("Games for Apple Arcade"). This privacy policy explains how we collect, use, share and protect your information when you use our Games for Apple Arcade, as well as your rights and choices about such collection, use and sharing.

By using our Games for Apple Arcade, you acknowledge that you have read and understand the terms of this privacy policy, including how we use personal information. Sega of America, Inc., located at the address set forth in Section 7 “Contact Us” is the data controller for the information collected via our Games for Apple Arcade.

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.

The privacy policy may be revised periodically, and any such revisions will be reflected by the “Last Updated Date” above. Please revisit this page to stay aware of any changes. If we make material changes to this privacy policy, we will provide you with additional notice of such changes by providing alerts within our Games for Apple Arcade.

1. Information we collect

We collect limited information about you in our Games for Apple Arcade. We collect:

(a) Game Profile Information

During your gameplay experience, the Game for Apple Arcade will generate non-personal information (for example, your progression through the game, high scores) about your Game for Apple Arcade experience.  This information is stored locally on your device and may also be saved to Apple’s servers (iCloud) in accordance with terms governing your relationship with Apple. We call this your “Game Profile”.

(b) Email address for customer support

If you choose to contact customer support, your communication to us will be sent via email. Our customer support platform will store your email address so we can reply to your message. We will delete the communication log shortly after completion of your customer support enquiry.

(c) Game Analytics

With your permission, we will collect anonymous data about your gaming experience. This data will be game event data – for example, your progression through the game, how long you play the game etc. We will ask for your permission before any data is sent to our servers, and this data will be anonymous.

2. How we use the information we collect 

We use the information we collect for the following purposes:

(a) Game Profile Information

Your Game Profile is required to record your performance through the Game for Apple Arcade. The Game Profile includes information such as the characters you have unlocked, the levels you have played and the last time you played the Game for Apple Arcade.

• Your Game Profile may be saved to iCloud to transfer your Game Profile to your other supported devices.

(b) Customer Support

We use personal information you provide via customer support requests to reply to your questions or queries, to provide customer support and resolve problems relating to any of our Games for Apple Arcade under the relevant terms of service. We may share non-personal information about your issues with the Games for Apple Arcade with our development team to identify areas and issues we can improve in our Games for Apple Arcade.

(c) Game Analytics

The analytics data we collect will be used to help us improve the game. Using the data, we will be able to see how users experience the game. It will highlight any areas that cause players friction and will allow us to make better decisions about the changes we make to the game.

3. When we disclose information 

In delivering the Games for Apple Arcade to you, we may disclose personal information provided in your customer support communications to:

• Companies within the SEGA group (which means Sega of America, Inc.’s subsidiaries and affiliates, our ultimate holding company and its subsidiaries and affiliates) who act for us for the purposes set out in this policy
• We use Zendesk to store our Customer Support communications
• If our business relating to the Games for Apple Arcade 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 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.

Personal information may be transferred to other countries where we or our service providers maintain operations. These countries may not have equivalent data protection laws to the country from where you access the Games for Apple Arcade 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. When we transfer 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 out of the European Economic Area, we will, in the absence of an EC adequacy decision relevant to the destination country 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.

4. Security and data retention 

We take reasonable physical, technical and organizational measures, to protect your information from unauthorized access and against unlawful processing, accidental loss, destruction and damage.

Your personal information (information provided in your customer support communications) will be retained by us for the duration of the enquiry. We will delete the communication log shortly after completion of your customer support enquiry.

We may retain a record of your stated objection to the processing of your data, 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 when you withdraw consent (as applicable) or at your request.

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 the Games for Apple Arcade at any time. 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.

Your game profile is stored locally on your device and in iCloud – we do not collect this, or any other personally identifiable data (other than information provided in Customer Support communications). In addition, you may contact us as described in Section 8 “Contact Us” to exercise any of your rights. You may also contact ESRB Privacy Certified at at https://www.esrb.org/privacy/contact or privacy@esrb.org.  

 If you remain unhappy with a response you receive, and are in the European Union, 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. Notice to California Residents

If you are a California resident, please also be aware that you are entitled to certain specific rights regarding your data under the California Consumer Privacy Act of 2018, as amended by the California Privacy Rights Act of 2020 (“CCPA”). California residents have the following rights:

• The right to know what personal information is being collected about them.
• The right to know whether their personal information is sold or disclosed and to whom.
• The right to say no to the sale of personal information.
• The right to access their personal information.
• The right to equal service and price, even if they exercise their privacy rights.

We comply with the CCPA. We do not engage in the collection or sharing of your personal information, except minimally as described above in Sections 1 and 2, as of the effective date of this Privacy Policy. We do not “share” or “sell” your personal information as defined under CCPA.

7. Children’s information 

If we learn that we have collected personal information of users under the age of 13 or other applicable age of consent, other than persistent identifiers for support of the internal operations of the Games for Apple Arcade (in the U.S.) and/or for our legitimate interests (outside the U.S.), then we 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.

8. 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,

140 Progress, Suite 100

Irvine, CA 92618

USA

You can also contact our Data Protection Officer at dataprivacy@segaamerica.com.

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