Privacy Policy

●Information Security and Privacy Policy

The Company recognizes the importance of information management and will make every effort to maintain all information that we manage or in our possession in accordance with the following policy.

1. Compliance with Laws and Regulations

●The Company will comply with relevant laws and regulations with regard to the handling of the information.

2. Acquiring Information

●The Company will acquire information by lawful and fair means.

3. Managing Information

●The Company will manage information in a manner that maintains the confidentiality, completeness, and availability thereof.

• ・Confidentiality: Safeguarding information from leakage to third parties
• ・Preventing access to information by unauthorized persons and disclosing information solely to persons who have obtained approval in a proper manner
• ・Completeness: Maintaining the accuracy and completeness of the information
  Allowing modification of the information and the program only by approved methods
• ・Availability: Ensuring the availability of the information system at all times by designated methods
  Avoiding circumstances wherein system failures and the like render the information system unavailable

●To prevent information loss, destruction, falsification, or leakage, the Company will take appropriate information management measures, including restricting and controlling access to the information, establishing controls on entry/exit at departments/divisions handling the information, implementing measures to prevent unauthorized access or system compromise due to computer viruses, and the like.

●When outsourcing the handling of the information to third parties, the Company will proceed according to established procedures to maintain confidentiality.

4. Organization and System

• ●The Company will appoint a person in charge of information management promotion and implement appropriate management of the information.
• ●For its employees (including all officers, regular employees, contract employees, dispatched employees, part-time employees, and the like; this definition applying hereafter), the Company will provide education and training on safeguarding and managing the information appropriately to ensure the appropriate handing of the information in day to day business operations.

5. Establishing, Implementing, Maintaining, and Improving the Information Management Program

• ●To enforce this Policy, the Company has established an information management program (including this Policy, “Information Management Rules,” and other rules and regulations) and will take all due steps to ensure that such information management program will be thoroughly communicated to the Company’s employees and other related parties and will be implemented, maintained, and improved on a continuing basis.

6. Handling of Personal Information

• ●In light of the importance of safeguarding Personal Information, the Company will comply with all applicable laws and regulations and the provisions specified in “Handling of Personal Information,” “Joint Use of Personal Information,” and “Handling of Specific Personal Information” to be specified separately, and handle the Personal Information to be collected by us in an appropriate manner.

• ●Handling of Personal Information
• ●Joint Use of Personal Information
• ●Handling of Specific Personal Information
• ●Retargeting Advertisement

●Handling of Personal Information

Based on the Information Security and Privacy Policy, the Company will handle the Personal Information that we manage or in our possession in an appropriate manner and in accordance with the following provisions and make every effort to maintain the Personal Information.

When acquiring Personal Information, the Company will clarify the purposes of use and use the Personal Information only within the scope of such purposes and only to the extent necessary for the performance of the corresponding operations.

Information to be acquired

Names, addresses, gender, birth dates, company or organization names, titles, phone numbers, e-mail addresses, play data logs, information regarding device identifiers, location data and communication records, and any other personal information necessary for the Company’s proper and efficient operations

Purposes of use

Customer information

• ・Responding to customer inquires or requests
• ・Providing customers with any information on the Company’s events, campaigns, questionnaires, and the like
• ・Distributing e-mail newsletters
• ・Contributing to the planning and development of the Company’s goods, services, and the like
• ・Marketing activities
• ・Accepting registrations and providing services with respect to the Company’s goods, services、 and the like
• ・Managing the records of customers using the services, summaries and results of events, and the like
• ・Any other matters necessary for the Company’s proper and efficient operations

Business partner information

• ・Various communications, orders accepted and placed, invoices and payments, and other matters related to transactions
• ・Providing business partners with any information on the Company’s goods, events, campaigns, questionnaires, and the like
• ・Contributing to the planning and development of the Company’s goods, services, and the like
• ・Marketing activities
• ・Starting, continuously engaging in, or managing any business transactions
• ・Any other matters necessary for the Company’s proper and efficient operations

Information on job applicants for recruiting new graduates and mid-carrier workers

• ・Contacting job applicants concerning recruitment/employment and management of recruitment/employment
• ・Any other matters necessary for the Company’s proper and efficient operations

Employee information

• ・Management of employees’ personnel/labor matters
• ・Management of employee duties and security management
• ・Any other matters necessary for the Company’s proper and efficient operations

• ●The Company may outsource the handling of the Personal Information to third parties who have executed nondisclosure or other necessary agreements, but only to the extent necessary to attain the purposes of use set forth above.
• ●Unless specified by laws or regulations, the Company will not provide the Personal Information to any third party without obtaining prior consent from the person in question.
• ●Before registering the Personal Information with the database and using such Personal Information jointly with third parties, the Company will clearly define the joint users, the scope of the data to be jointly used, and purposes of use. The Company will also appoint a person in charge of management thereof and will post descriptions of these issues and the purpose of such joint use on the Company’s website and the like.
• ●The Company will take adequate steps to maintain the accuracy of the Personal Information and to ensure the secure management of the Personal Information.
• ●The Company will promptly respond to and comply with requests for disclosure, correction, suspension of use, deletion, or the like concerning Personal Information, in accordance with the provisions of laws and regulations.

Please contact the inquiry desk below with comments, questions, complaints, and the like regarding the handling of the Personal Information by the Company.
Sammy Corporation
Personal Information Inquiry
Sun Shine 60, 3-1-1 Higashi-ikebukuro, Toshima-ku, Tokyo 170-6029
For inquiries, click here.

●Joint Use of Personal Information

Sega Sammy Holdings Inc. as well as its subsidiaries and affiliates, including Sammy Corporation (the “Sega Sammy Group”), will jointly use the Personal Information of customers and business partners as follows:

1. Personal Information to be jointly used

• ・Names, addresses, gender, birth dates, company or organization names, titles, phone numbers, e-mail addresses, play data logs, information regarding device identifiers, location data and communication records, and any other personal information of customers and business partners necessary for the Company’s proper and efficient operations

2. Scope of joint users

• ・Any company within the Sega Sammy Group
• ・For more information regarding the Sega Sammy Group excluding Saga Sammy Holdings Inc., please see the Sega Sammy Group list.

3. Purpose of use of the companies in the Sega Sammy Group

• ・Providing customers with any information on the Company’s goods, events, campaigns, questionnaires, and the like
• ・Distributing e-mail newsletters
• ・Contributing to the planning and development of the Company’s goods, services, and the like
• ・Marketing activities
• ・Managing the records of customers using the services, summaries and results of events, and the like
• ・Accepting registrations and providing services with respect to the Company’s goods, services, and the like
• ・Contacting job applicants, making decisions regarding their employment, and managing job applicants’ information
• ・Conducting background checks on the Sega Group’s existing or potential partners whether such business partners or related entities/individuals belong to and/or associated with an organized crime group (or its members or entities/individuals affiliated therewith) in order to determine whether to start, continuously engage in, or otherwise conduct any business transactions with such business partners
• ・Any other matters necessary for the Company’s proper and efficient operations

4. Contact information on the management of the Personal Information

Sammy Corporation
Personal Information Inquiry
Sun Shine 60, 3-1-1 Higashi-ikebukuro, Toshima-ku, Tokyo 170-6029
For inquiries, click here.

●Handling of Specific Personal Information

Based on the Information Security and Privacy Policy, the Company will strive to handle the Specific Personal Information that we manage or in our possession in an appropriate manner and in accordance with the following:

Name of business operator

Sammy Corporation

Compliance with applicable laws and regulations, guidelines, and the like

The Company will handle the Specific Personal Information in an appropriate manner in compliance with the “Act on the Use of Numbers to Identify a Specific Individual in the Administrative Procedure,” “Act on the Protection of Personal Information,” and “Guidelines for Proper Handling of Specific Personal Information (Business Operators).”

Safety management measures

To specify safety management measures for the Specific Personal Information at the Company, the Company has established the information management program, comprised of the Information Security and Privacy Policy, rules based thereon, and various other rules and regulations.

Purposes of Use

The Company will use the Specific Personal Information for the following purposes:

(1) Matters related to the Individual Numbers of the Company’s employees (including dependent family members and/or past employees) as follows:

• (i) Withholding tax
• (ii) Payment of salaries and the like
• (iii) Personal resident tax
• (iv) Health insurance
• (v) Employees’ pension
• (vi) National pension
• (vii) Company pension
• (viii) Unemployment insurance
• (ix) Industrial accident compensation insurance

(2) Matters related to the Individual Numbers of persons other than the Company’s employees as follows:

• (i) Payment records of compensations, fees, and the like
• (ii) Payment records of rents and the like for real estate
• (iii) Payment records of consideration for sales of real estate and the like

(3) Any other matters related to the above

●Retargeting Advertisement

Advertisements distributed by third parties including Yahoo Japan Corporation may be posted on the Company’s website. The relevant third parties may obtain cookie information and the like concerning users who visit our website and make use of such information.

Cookie information and the like obtained by the relevant third parties will be handled in accordance with their privacy policies.

The user may visit the opt-out page established within the relevant third parties’ websites to disable use of cookies and the like by the relevant third parties for the distribution of targeted advertisements.

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