3. ONLINE AND MOBILE APP ADVERTISING

ONLINE ADVERTISING ON OUR WEBSITES AND NON-SEGA PROPERTIES

We may allow third-party advertising technologies (e.g., ad networks and ad servers such as Google’s ad services, and others) on our Products that use cookies to deliver relevant and targeted content and advertising to you on the Products and other websites you visit and applications you use. The ads may be based on various factors such as the content of the page you are visiting, information you provide, your searches, demographic data, and other information we collect about you. These ads may be based on your current activity or your activity over time and across other websites and online services and may be tailored to your interests. See also our Cookies Policy for more information. We do not share your age or gender with third parties to enable them to deliver targeted advertising to you based on your age or gender in our mobile apps, except that we may inform third parties if we know that you are under the age of consent (see Section 8: Children's Information).

The use of cookies or other tracking technologies that may be placed on devices you use to access our Products by unaffiliated third parties is governed by the privacy policies of those third parties. If you are interested in more information about tailored browser advertising and how you can generally control cookies from being put on your devices to deliver tailored advertising, you may visit the Network Advertising Initiative’s Consumer Opt-Out link or the Digital Advertising Alliance’s Consumer Opt-Out link to opt out of receiving tailored advertising from companies that participate in those programs.

For additional ways to opt-out of targeted advertising activities under applicable laws, see the “Your Choices and Rights” section below.

Please note that these opt-outs apply per browser and per device, so you will have to opt out for each device—and each browser on each device—through which you access our Products. In addition, the opt-outs do not apply to advertisements in mobile applications. See the “Mobile App and In-Product Advertising” section below to learn how to opt out of mobile app advertising.

MOBILE APP AND IN-PRODUCT ADVERTISING

You may also receive tailored in-app advertisements when using our mobile apps. We may use third-party service providers to deliver ads on mobile apps or for mobile app analytics.  Each operating system (for example iOS for Apple phones, Android for Android devices, and Windows for Microsoft devices) provides its own instructions on how to express certain choices regarding the delivery of tailored in-application advertisements. Because we do not control how the applicable Platform Operator enables these choices receiving personalized in-application advertisements, you should review the support materials and/or the device settings for the respective operating systems for information on opting out of tailored in-application advertisements.  We do not share your age or gender with third parties to enable them to deliver targeted advertising to you based on your age or gender in our mobile apps, except that we may inform third parties if we know that you are under the age of consent (see Section 8: Children's Information).

Further information about the protection of your privacy can be found in the relevant third party entity’s privacy policy. For links to these, and details of partners who are integrated into our mobile titles and websites, please see Appendix A of this Privacy Policy.

NOTICE CONCERNING DO NOT TRACK

Do Not Track (“DNT”) is a privacy preference that is available in certain web browsers. We do not currently recognize or respond to browser-initiated DNT signals. Please note that Do Not Track is a different privacy mechanism than the user “preference signal” referenced in the “Your Choices and Rights” section below, which is a legally recognized browser-based control that indicates whether you would like to opt out of processing of your personal information for certain purposes, such as the “sale” or “sharing” of your information or the disclosure of your personal information for targeted advertising purposes, under applicable laws.

4. HOW WE DISCLOSE INFORMATION

We or our service providers may disclose the information we collect about you (subject to legally required security, contractual and transfer safeguards).  These are some of the partners we may disclose your personal information to: 

(a) SEGA companies within the wider SEGA Group;  

(b) Service providers;

(c) Platform Operators;

(d) Other unaffiliated third parties, including third parties we collaborate with in connection with integration, co-marketing, and certain other coordinated efforts as well as third parties whose offers we believe you may value (e.g., advertising partners for the service of advertisements within our Products); 

(e) Others at your direction and with your consent;

(f) New or potentially new owners or re-organized entities and their advisors in the event of a business restructure, transfer, merger, dissolution sale, purchase, joint venture, or similar event involving our business (including in contemplation of such transactions); and  

(g) Law enforcement agencies/authorities or others, when we are under a duty or are authorized by law for law enforcement purposes or to enforce relevant terms of service and any other agreement or to protect our rights or the rights of third parties. 

In delivering our Products to you, we may disclose your personal information to: 

* Companies within the SEGA Group (which means SEGA Entities which are our parent and affiliated companies, our ultimate holding company and its subsidiaries and affiliates) who act for us for the purposes set out in this policy.  

* Third party service providers in order to undertake various activities or services on our behalf in supporting our Products. This includes payment processing providers facilitating credit and payment card transactions, website and application support and hosting providers for online videogame services and software downloads and providers for the delivery of promotional, digital advertising or other communications.

* Other unaffiliated third parties such third parties we collaborate with in connection with integration, co-marketing and certain other coordinated efforts and third parties whose offers we believe you may value.

* Others at your direction and with your consent or in conjunction with your participation in sweepstakes and contests.

* In the event of sale (of some or all of our assets), transfer, merger, reorganization, dissolution, or similar event involving our business (including in contemplation of such transactions), your personal informationmay be among the transferred business assets. If such transfer is subject to any mandatory restrictions under applicable laws, we will comply with those restrictions. 

* We may use the information that you provide if we are under a duty to disclose your personal informationin order to comply with (and/or where we believe we are under a duty to comply with) any legal obligation; or if we believe in good faith that disclosure is reasonably necessary to: (i) enforce the relevant terms of service and any other agreement; (ii) respond to claims that any content violates the rights of third parties; or (iii) protect the rights, property, or personal safety of SEGA, users of our Products, or others. This includes exchanging information with other companies and organisations for fraud protection, spam/malware prevention, and similar purposes, such as credit agencies, law enforcement or government bodies or the courts in connection with a criminal investigation or suspected illegal activity.

5. SECURITY AND DATA RETENTION

We place great importance on the steps we take, including physical, technical and organisational measures, to protect your personal information from unauthorized 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 informationtransmitted to, through, or on our Products and that any such transmission is at your own risk.

When 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 unauthorized transactions entered into using your personal information, including but not limited to your username, and/or password. If you suspect unauthorized access, you should change your password, using a strong password immediately.  

We will retain your personal information for the duration of your use or access to our Products and may retain it for a period after this time where we still have a legitimate interest, e.g., to resolve disputes, enforce our terms with you and comply with applicable laws and obligations. This may include retention necessary to meet our tax reporting requirements as well as time required to fulfil transactions you have requested, 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. In determining how long to retain information, 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 information at the point this information is no longer needed by us for our business or legal purposes.  We may retain cached or archived copies of your personal information. 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.