Sega of America, Inc. Privacy Policy (Feb 2022)

Table of Contents

Last Updated
February 2022

For further information regarding third party partners integrated into our titles, please visit Appendix A

For "Interest Based Ad Disclosure" and "Precise Location Data Disclosure", please see section 11.

Introduction

Sega of America, Inc., 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 use our mobile, online and downloadable products and services (together, the "Products"). This Privacy Policy explains how we collect, use and protect your personal information when you use our Products or 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 using our Products you acknowledge that you have read and understood the terms of this Privacy Policy, including how we use your personal information.

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. In addition, for U.S. users of our Products, we adhere to the Digital Advertising Alliance’s Self-Regulatory Principles for the Mobile Environment

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 be cautious whenever disclosing personal information – in our Products or elsewhere. 

SUMMARY

Our Privacy Policy will help explain what information we collect, how we use it and what options you have in relation to it.

We will only collect and process personal information about you where we have a lawful basis in your country. As stated throughout this Privacy Policy, our lawful bases include consent (where you have given consent to, for example, receive updates and marketing emails), contract (where processing is necessary for the performance of a contract with you (e.g. to supply the Products you have requested)), to comply with our legal obligations, and our general 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 
(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. We also receive data about you from partners to improve the performance of 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) Sweepstakes:information you provide to us when you participate in our sweepstakes
(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) LiveOps software:information that is processed by third party LiveOps tools when you use our Products
(l) User Acquisition and Core / Custom / Lookalike Audiences:information that is collected to help us acquire new users for our Products and to build Custom and Lookalike Audiences
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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;
(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;
(ii)    to understand how you engage with our marketing campaigns; and
(iii)    to gain an understanding of 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)    Information about your participation in sweepstakes:

(i)    to verify your identity; and
(ii)    to distribute prizes to you.

(i)    Information about your use of social media plug-ins:

(i)    to allow you to easily share our content via social media platforms.

(j)    Information from anti-cheat and anti-hacking technologies:

(i)    to detect illegal or malicious activity in our Products.

(k)    Information from live-ops software:

(i)    to provide certain in-game features and functionality.

(l)    Information for User Acquisition and Core / Custom / Lookalike Audiences:

(i)    to acquire new users for our Products and help us build Core, Custom and Lookalike Audiences for analytics and marketing purposes.
 

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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, Amazon, Samsung, Sony PlayStation, Nintendo, Microsoft Xbox, and other partners who carry out various activities and services to support our Products (collectively, the “Platform Operators”); 
(c)    Advertising partners for the service of advertisements within our Products.
(d)    Marketing partners for marketing or promotions such as Mailchimp, based on your communication preferences;
(e)    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 
(f)    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.

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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. 

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 for our legitimate operations, under our terms with you and in accordance with applicable laws.

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5. Your choices and rights

You have options and choices over how we use your personal data. 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.

If you wish to amend the personal data that you use to access our Products; object to our processing of your personal data;  or would like us to correct, erase, restrict, or move your personal data, you can contact us using the details below. If you do not want us to process and/or access your personal data, you may be unable to use some of our Products.

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. 

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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 underage users other than as permitted by law in support of our internal operations.

In this privacy policy any reference to underage users refers to those under the age of consent to the processing of personal data in their country of residence:

  • Croatia, Germany, Hungary, Ireland, Luxembourg, Malta, Netherlands, Poland, Romania, Slovakia - 16 or under
  • Czech Republic, France, Greece, Slovenia - 15 or under
  • Austria, Bulgaria, Cyprus, Italy, Lithuania, Spain - 14 or under
  • United States, United Kingdom and any EU countries not listed above - 13 or under
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7. California Residents

The California Consumer Privacy Act 2018 (the “CCPA”), Privacy Rights for California Minors in a Digital World and the California Shine the Light law provide California residents with certain rights regarding the processing of their personal data.

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8. Nevada Residents

Nevada law provides Nevada residents with certain rights regarding the processing of their personal data.

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9. Mobile Applications

Several of our mobile products serve advertising, and some of our partners collect data directly from your device. Depending on your region and device, you can control our partners’ access to data.

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10. 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: 

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

 

If you are located in the United Kingdom (UK) you can contact Sega of America’s UK representative at: 

ATTN: SOA DPO 

SEGA Europe Ltd 

27 Great West Road 

Brentford, Middlesex, TW8 9BW 

 

You can also contact our data protection officer at dataprivacy@segaamerica.com.  

For further information regarding third party partners integrated into our titles, please visit Appendix A