SEGA Europe Limited Privacy Policy.
Introduction
SEGA Europe Limited, its subsidiaries and affiliates (together “SEGA”, individually a “SEGA Entity”) are committed to protecting the privacy and security of your personal data. SEGA collects different types of information from you when you use our mobile, online and downloadable products and services (together, the "Products").
This Privacy Policy explains how we collect, use and protect your personal data when you use our Products or interact with us.
By using our Products you acknowledge that you have read and understood the terms of this Privacy Policy, including how we use your personal data.
The data controller is responsible for collecting and using your personal data. To comply with data protection legislation, the data controller will be the SEGA Entity with whom you contract for a Product. See the '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 our Products. We want you to enjoy using our Products and urge you to follow common sense whenever disclosing personal data – in our Products or elsewhere.
The Products may contain links to third-party websites, plug-ins, features, or services. If you choose to use these sites or features, please note that we do not have control over the third parties that operate these websites and services and are not responsible for their content or privacy practices. We encourage you to read their privacy policies before using their websites or services or giving them your personal information.
If you are a business customer or contact of SEGA, including suppliers, vendors, business partners, and similar businesses, please visit Appendix A of this Privacy Policy for information about our processing practices.
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 clicking the ‘learn more’ link below.
We will only collect and process your personal data where we have a lawful basis to do so. As stated throughout this Privacy Policy, our lawful bases include consent, for example, where you have agreed to receive updates and marketing emails from SEGA), contract (where processing of your personal data is necessary for the performance of a contract with you (e.g. to supply the Products you have requested), compliance with our legal obligations, and/or our legitimate business interest in administering our business operations.
1. Information we collect and receive
We collect personal data 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 our Products, or when you wish to register to attend an event or programme, hosted or sponsored by SEGA |
| (b) Billing information: | provided by you and/or third party stores |
| (c) Technical and device information: | information from your mobile or computer device when you use our Products |
| (d) Feedback / surveys / user research: | your questions, suggestions or views on our 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 |
| (f) Information from publicly available online sources: | information that has been made publicly available by you on third party platforms (such as Facebook or Twitter) and which relates to our Products |
| (g) Information about your use of our Products: | information we collect when you use our Products |
| (h) Competitions: | information you provide to us when you participate in our competitions |
| (i) Social media plug-ins: | information that is collected when you utilise third party social media plug-ins relating to our Products |
| (j) Anti-cheat and anti-hacking technologies: | information that helps us to ensure our Products are used in a fair and lawful manner |
| (k) Information from live operations software tools used to make changes, updates or improvements to our Products (“LiveOps Software”): | information that is processed by third party LiveOps tools when you use our Products |
| (l) User Acquisition/Attribution and Core / Custom / Lookalike Audiences: | information that is collected to help us acquire new users for our Products and to build Core, Custom and Lookalike Audiences |
Read further below for more details on the information we collect and/or receive from you.
2. 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 identify you when you sign-in;
(iii) to give you access to your user preferences;
(iv) to contact you for your views on our Products;
(v) to notify you of changes or updates to our Products; and
(vi) for marketing purposes, based on your communication preferences.
(B) BILLING INFORMATION:
(i) to verify your purchase of our Products and process any refunds;
(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 our Products by seeking to detect and prevent fraud or other acts in breach of our user agreements or policies relevant to our Products.
(C) TECHNICAL AND DEVICE INFORMATION:
(i) to provide you with an optimal experience;
(ii) to understand how you interact with our Products
(iii) to provide Products you request;
(iv) to measure and analyse the use and effectiveness of our Products;
(v) to understand which of your devices are using our Products and playing our videogames;
(vi) to provide safe and fair gaming environments;
(vii) to customise and optimise the targeting of our advertising both within our Products and across our websites;
(viii) to operate and improve our Products; and
(ix) to fix errors.
(D) FEEDBACK / SURVEYS / USER RESEARCH:
(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 our 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.
(F) INFORMATION FROM PUBLICLY AVAILABLE ONLINE SOURCES:
(i) to understand the community sentiment about our Products.
(G) INFORMATION ABOUT YOUR USE OF OUR PRODUCTS:
(i) to track the performance of our Products;
(ii) to communicate with our platform operators and partners; and
(iii) to improve our advertising and targeting systems.
(H) COMPETITIONS:
(i) to verify your identity; and
(ii) to distribute prizes to you.
(I) SOCIAL MEDIA PLUG-INS:
(i) to allow you to easily share our content via social media platforms.
(J) ANTI-CHEAT AND ANTI-HACKING TECHNOLOGIES:
(i) to detect illegal or malicious activity in our Products.
(K) LIVEOPS SOFTWARE:
(i) to provide certain in-game features and functionality.
(L) USER ACQUISITION / ATTRIBUTION AND CORE / CUSTOM / LOOKALIKE AUDIENCES:
(i) to acquire new users for our Products, to measure the performance and effectiveness of our marketing campaigns and help us build Core, Custom and Lookalike Audiences for analytics and marketing purposes.
Read further below for more details on how we use the information we collect and/or receive from you.
3. 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 data with:
(a) SEGA companies within the wider SEGA group;
(b) Third party platform operators such as Valve who operate the Steam digital download platform, Epic, Apple, Google Play, Sony PlayStation, Nintendo, Microsoft Xbox, and other partners who carry out various activities and services to support our Products (collectively, the “Platform Operators”);
(c) Marketing partners for marketing or promotions such as Mailchimp, based on your communication preferences;
(d) New owners or re-organised entities and their advisors in the event of a business restructure, sale, purchase or joint venture affecting our business; and
(e) Law enforcement agencies/authorities, when we are under a duty or are authorised by law for law enforcement purposes.
Your personal data 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 our Products, but we will ensure that we rely on appropriate safeguards.
Read further below for more details on when we share the information which we collect and/or receive from you.
4. Security and data retention
Your privacy is important to us and we place great importance on the steps we take, including technical and organisational measures to protect your information from unauthorised 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 transmitted to, through, or on our Products and that any such transmission is at your own risk.
Your personal data 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.
Where you have chosen a password which allows you to access any of our 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 unauthorised transactions entered into using your personal data, including but not limited to your username, and/or password. If you suspect unauthorised access, you should change your password, using a strong password immediately.
Your personal data 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, any game “sun-setting” requirements or to identify, issue or resolve legal proceedings or disputes, fraud prevention, and related security purposes. When determining how long to retain personal data, we consider 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 data 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.
5. Your choices and rights
You may be required to register or sign in to use or access some of our Products, and may need to provide personal data to create a user profile which is associated with your use of our Products. You have options and choices over how we use your personal data. We also provide you with tools to access and update specific information relating to your use of our Products at any time. If you need to sign in to access certain Products, you can update and amend your key contact information directly.If you sign up to our marketing communications, you will be asked to confirm your communication preferences and will be given the opportunity to unsubscribe at any time. Please note that it may take us some time, consistent with our legal obligations, to process your request. Even if you opt out from receiving marketing messages from us, you may continue to receive service updates from us, such as to confirm your purchase of one of our Products, updates relating to our policies and practices, or other communications regarding our relationship or transactions with you. 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, if relevant.
If you wish to amend the personal data that you use to access our Products or would like us to correct, erase, restrict, object to, or move your personal data, you can make a support request, selecting ‘DATA REQUESTS’ from the drop down menu on our website. You can also contact us by post or phone using the details below. Please note that if you do not want us to process and/or access your personal data, you may be unable to use some of our Products.
By telephone on: +44 845 301 5502
By writing to us at:
SEGA Europe Limited
Customer Services
27 Great West Road
Brentford
Middlesex
TW8 9BW
United Kingdom
We respect the rights you may have under applicable law to request access to your personal data 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 data, 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.
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 - for Europe, or https://ico.org.uk/make-a-complaint - for the United Kingdom).
NOTICE OF RIGHT TO OPT OUT OF SALES OF PERSONAL INFORMATION AND PROCESSING/SHARING OF PERSONAL INFORMATION FOR TARGETED ADVERTISING PURPOSES
Depending on your jurisdiction, 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 explained in the “When we share information” section above, we sometimes disclose information to third parties we collaborate with or that provide offers that we think may be of value to you. This disclosure of information may be considered a “sale” or “sharing” under applicable laws.
We also provide personal information to third-party advertising providers for targeted advertising purposes, so that we can provide you with more relevant and tailored ads regarding our services, or use analytics partners to assist us in analyzing use of our services and our user/customer base. The disclosure of your personal information to these third-parties to assist us in providing these services may be considered a “sale” of personal information under applicable law, or, the processing/sharing of personal information for targeted advertising purposes.
If you would like to opt out of our online disclosure such as through cookie and pixel technology of your personal information for purposes that could be considered “sales” for those third parties' own commercial purposes, or “sharing” for purposes of targeted advertising, please go to the respective SEGA property (e.g., sega.com, sega.co.uk, or the specific game website or app) and click on the “Your Privacy Choices” link in the footer of the website or settings menu of the app. You must make this choice on each site/app on each browser/device you use to access the services. You must also renew this choice if you clear your cookies or your browser is set to do that. You can also submit a request to opt out of the use of your email address and other personal information related to that email address for targeted advertising purposes by emailing us at dpo@sega.co.uk.
Please note that if you have a legally-recognized browser-based opt out preference signal turned on via your device browser, we recognize such preference in accordance with applicable laws.
6. 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 data or non-personally identifiable information from users under 13 years of age, other than as permitted by law in support of our internal operations.
If SEGA learns that personal data of users under the age of 13 has been collected, other than for support of our internal operations, SEGA will take reasonable steps to remove such information. If you believe that we may have unintentionally collected personal data about your child who is under 13 years of age, you may contact us using the details provided below.
7. Californian Privacy Notice
The Californian 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 Californian Shine the Light law provides Californian residents with certain rights regarding the processing of their “ personal information” or “sensitive personal information”, as defined under the CCPA, and as used throughout the remainder of this section 7.
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.
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) |
|---|---|---|
Identifiers
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Demographic information such as age or date of birth and gender |
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| Customer service information such as questions and other messages you address to us directly through online forms, by email, over the phone, or by post |
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| Financial information such as credit card information stored by our payment processors on our behalf |
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| Transactional information such as information about your transactions with us and related to your attendance at events or programs |
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| User-generated content such as any user-generated content you voluntarily decide to provide through the Products, including photographs, or other information you provide in connection with your account |
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Survey, research, feedback, or sweepstakes information such as information you provide in response to a survey or sweepstakes on in relation to the Products |
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| Internet network and device activity data such as browsing information and usage information |
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| Geolocation information Such as your approximate location based on IP address |
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Information about others such as if you submit information about others |
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| Other information Any other information that you provide in the course of using the Products |
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As explained in the ”When we share information” section above, we sometimes disclose information to third parties we collaborate with or that provide offers that we think may be of value to you. This disclosure of information may be considered a “sale” or “sharing” under the CCPA. We also provide personal information to third-party advertising providers for targeted advertising purposes, so that we can provide you with more relevant and tailored ads regarding our services, or use analytics partners to assist us in analysing the use of our services and our user/customer base. The disclosure of your personal information to these third parties to assist us in providing these services may be considered a “sale” of personal information under the CCPA, or the “sharing” of your personal information for purposes of “cross-context behavioral advertising.”
The following chart lists the categories of personal information we have sold or shared over the last 12 months and the categories of third parties to which we have sold or shared such personal information:
| Category of personal information | Categories of third parties to which we have “sold” or “shared” such personal information |
| Identifiers | Advertising partners and advertisers; Unaffiliated third parties for their advertising purposes; Analytics providers |
| Demographic information | Advertising partners and advertisers; Unaffiliated third parties for their advertising purposes; Analytics providers |
| Transactional information | Advertising partners and advertisers; Unaffiliated third parties for their advertising purposes; Analytics providers |
| User-generated content | Advertising partners and advertisers; Analytics providers |
| Survey, research, or sweepstakes information | Unaffiliated third parties for their advertising purposes; Analytics providers |
| Internet network and device activity data | Advertising partners and advertisers; Analytics providers |
| Geolocation | Advertising partners and advertisers; Analytics providers |
If you would like to opt out of our online disclosure such as through cookie and pixel technology of your personal information for purposes that could be considered “sales” for those third parties’ own commercial purposes, or “sharing” for purposes of targeted advertising, please go to the respective SEGA property (e.g., sega.co.uk, sega.com, or the specific game website or app) and click on the “Your Privacy Choices” link in the footer of the website or settings menu of the app.” You must make this choice on each site/app on each browser/device you use to access the services. You must also renew this choice if you clear your cookies, or your browser is set to do that. You can also submit a request to opt out of the use of your email address and other personal information related to that email address for targeted advertising purposes by emailing us at dpo@sega.co.uk. Depending on your jurisdiction, you may be permitted to designate an authorised agent to submit such requests on your behalf. Please note that we do not knowingly sell the personal information of children under 16 years of age without legally required affirmative authorization.
Please note that if you have a legally recognised browser-based opt out preference signal turned on via your device browser, we recognize such preference in accordance with applicable laws.
Other California Rights
The 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 dpo@sega.co.uk. 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 dpo@sega.co.uk. 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. Your questions and how to contact us
If you have any questions or comments about this Privacy Policy you can contact us by making a support request on our website, or you contact us as set out below:
By telephone on: +44 845 301 5502
By writing to us at:
SEGA Europe Limited
Customer Services
27 Great West Road
Brentford
Middlesex
TW8 9BW
United Kingdom
You can also contact our data protection officer at dpo@sega.co.uk.
Appendix A
Information from suppliers, vendors, business partners, and similar businesses
- Contact and Business Information. If you are a company or other organisation that we engage with, or a representative of the foregoing, we may collect your name, phone number, email address, and postal address, government identifier, and business name, industry, locations, other information related to your employer, and any other information or personal data that you choose to provide us, including through third-party portals and platforms.
- Financial and Transactional Information. If we need to make payments to you or receive payments from you, we may collect financial account and related transactional information.
- Communications. If you contact us, we may receive personal data such as your name, email address, and phone number. We will also receive the contents of any communications you have with us. This might include requests, questions, and/or issues regarding our Products, services we provide to each other, an account you hold with us, or other topics you might raise.
- Events and Programmes. If you register for or attend an event or programme that we host, sponsor, or attend, we may receive information such as your name, email address, phone number, and other personal data related to your attendance at the event or program from those who interact with or express interested in SEGA or our Products.
- Surveys, Promotions, Competitions and Gifting. If you decide to participate in any surveys, promotions, competitions or our gifting activities, you may provide certain personal data, such as basic contact information and other information relevant to the survey, promotion, competition or gifting activity.
We will process and retain this information and the related personal data for as long as necessary to perform our legitimate business activities in accordance with applicable laws and our business data retention policy.