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Mobile Application Privacy Policy

SEGA Mobile Application Privacy Policy - Last Updated on April 26, 2016

 

Interest Based Ad Disclosure 

Precise Location Data Disclosure

 

Sega of America, Inc. and Sega Networks Inc. and certain of their affiliate companies (collectively, “Sega” or “we”) respect the privacy rights of our consumers and we are committed to protecting the personal information collected about you. To further this commitment, we have adopted this Mobile Application Privacy Policy (“Mobile Privacy Policy” or “MPP”) to help you make an informed decision about whether to use or continue using any of Sega’s mobile products or services (“App(s)”). This Mobile Privacy Policy will inform you about Sega’s policies and procedures regarding the collection, use and disclosure of your user information.

By using Sega Apps, you signify your assent to this Mobile Privacy Policy.

This Mobile Privacy Policy and the certification seal shown in this MPP confirm that Sega is a valid licensee, and participating member, of the Entertainment Software Rating Board’s Privacy Certified Program (“ESRB Privacy Certified”). To protect your privacy, we have voluntarily undertaken this privacy initiative and have had all of Sega’s Apps where this MPP is posted, 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 frequent audits of our Apps and other enforcement and accountability mechanisms administered independently by ESRB Privacy Certified. In addition, for U.S. users of our Apps, we adhere to the Digital Advertising Alliance’s Self-Regulatory Principles for the Mobile Environment.

This MPP may be revised periodically and this 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 MPP, we will provide you with additional notice of such changes by updating the description of the App in the applicable App store or by providing in-App alerts. Your continued use of the Apps shall constitute your agreement to this MPP and any future revisions.

 

Table of Contents

 

1. The Information Sega Collects
2. The Way Sega Uses Information
3. IBA Disclosure -Third Party Advertisers
4. When Sega Discloses Information
5. Precise Location Data
6. Your Choices
7. Sega’s Commitment to Data Security
8. Questions or Comments about this Privacy Policy

 

 

1. The Information Sega Collects

 

This MPP applies only to information submitted and collected by Sega via its Apps. The third party online/mobile store from which you purchase and/or install the Apps may also collect and use personal and non-personal information about you. This MPP does not apply to information that may be collected by such third party application store, and Sega is therefore not responsible for the information collected by such third party.

User-Provided Personal Information

Although you may provide certain personally identifiable information (such as your phone number, e-mail address, credit card or other payment information, etc.) when purchasing an App, this information is provided to the online/mobile application store in connection with your purchase and/or registration of the App. The online/mobile application store providers do not share your information with Sega. Sega will not receive or retain any of the personally identifiable information you share with such store providers in connection with your use of the App. The information that we collect through your download and use of the Apps is limited to the public profile information within your social media profile on Google+, Facebook, and/or Twitter, if you choose to register your App account via such social media providers. This information may include your first and/or last name, profile picture, and e-mail address.

For the support of internal operations, Sega collects your device identifier (“device ID”) and IP address. We do not access or store information that you have saved on your mobile device such as contacts and appointments. In addition, if permitted by your mobile device settings, the App may provide, to Third Party Advertisers, (i) your device ID (as further described in Section 3  and (ii) your precise location data (as further described in Section 5 ).

Children’s Information

Protecting the privacy of young children is especially important to Sega. For that reason, Sega does not knowingly collect or maintain personally identifiable information or non-personally identifiable information from users under 13 years of age, other than as permitted by law in support of the internal operations. If Sega learns that personally identifiable information of users under the age of 13 has been collected, other than for support of the internal operations, Sega will take reasonable steps to remove such information. If you believe that we may have unintentionally collected personal information about your child under 13 years of age, you may contact us at:

Sega Networks Inc.
Customer Service Department
612 Howard Street
Suite 200
San Francisco, CA 94105
privacy@sega.net

Anonymous Information

This is information that does not directly or indirectly identify you as an individual user. Sega and other third parties may passively collect non-personal information from you when you access or use Apps. We may collect:

  • Imprecise location information, either provided by you or your mobile device interacting with one of our App(s). In addition, certain Location data may consist of personally identifiable information: See Section 5 “Precise Location Data” for additional information);
  • Usage, viewing and technical data; and
  • Any other information (such as device type) that may be passively collected by third parties (such as ad networks on free-to-play Apps).

 

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2. The Way Sega Uses Information

 

We may use certain information (such as user usage data, IP addresses, device ID, browser type, clickstream data, cookies, etc.) to improve the quality and design of the Apps and to create new features, promotions, functionality, and services by storing, tracking, and analyzing user preferences and trends.

 

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3. IBA Disclosure - Third Party Advertisers

 

Certain Sega Apps are currently supported by third party ad servers or ad networks that serve advertisements (“Third Party Advertisers”), including behavioral or interest based advertising (“Interest Based Advertising”), within the Sega Apps. These Third Party Advertisers use technology to send, directly to your mobile device, the advertisements and links that appear in the Sega Apps. They may automatically receive your device ID, IP address or geo-location data when this happens. They may also use other technologies (such as cookies, JavaScript, or Web Beacons) to measure the effectiveness of their advertisements and to personalize the advertising content you see. Please see this list of our Third Party Advertisers for certain Sega Apps, and their respective policy policies for information regarding their privacy practices.

Opt-Out for Interest Based Advertising

Your mobile device may allow you to opt out of certain Interest Based Advertising.

iOS – On your iOS device (iPhone or iPad), open “Settings > Privacy > Advertising” and turn on “Limit Ad Tracking” to opt-out of interest based ads. Please see additional information from Apple here: https://support.apple.com/en-us/HT202074

Android – Open the Settings app on your Android phone, tap Ads and enable “Opt out of interest based ads”.

Please note that if you opt of certain Interest Based Advertising, you may continue to receive contextual ads based on other non-personal information, such as ads related to the content of the App you are using.

 

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4. When Sega Discloses Information

 

We may share non-personally-identifiable information (such as anonymous user usage data, mobile device type, etc.) with interested third parties to assist them in understanding the usage patterns for certain content, advertisements, promotions and/or functionality on Sega Apps. In addition, certain Third Party Advertisers may collect limited personally identifiable information, such as device ID, IP address or geo-location data, as further described in Sections 3 and 5.

We may receive and release personally identifiable information and/or non-personally-identifiable information if required to do so by law, or in the good-faith belief that such action is necessary to comply with state and federal laws, or respond to a court order, subpoena, or search warrant.

In instances when Sega is provided with personally identifiable information and/or non-personally-identifiable information, we reserve the right to disclose such information that we believe, in good faith, is appropriate or necessary to enforce our Terms of Service (if applicable), take precautions against liability, to investigate and defend ourselves against any third party claims or allegations, to assist government enforcement agencies, to protect the security or integrity of our Apps, and to protect the rights, property, or personal safety of Sega, our users or others.

 

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5. Precise Location Data

 

Certain Third Party Advertisers in Sega Apps may collect precise location data, or street-level location information, about you. Your mobile device may allow you to opt out of the collection of Precise Location Data by the Third Party Advertiser in the Sega App, as further described below.

iOS – In order to disable the collection of Precise Location Data on iOS, you may turn Location Services off for the applicable Sega App via the menu “Settings > Privacy > Location Services”. Then select the applicable Sega App and set the “Share My Location” status to “Never”. Please see additional information from Apple here: https://support.apple.com/en-us/HT203033

Android (6.0 / Marshmallow and higher) - In order to disable the collection of Precise Location Data on Android, you may turn Location off for the applicable Sega App via the menu “Settings > Apps > [applicable Sega App] > Permissions > Location”.  Then turn off the “Location” button.

 

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6. Your Choices

 

Some Sega Apps are free-to-play and supported by advertisements. In these instances, you may not opt out of receiving such advertisements. For those Sega Apps that you pay a fee, there may be specific targeted advertising. If you do not wish to be served advertisements, please do not use our Apps. Please contact Sega via email at privacy@sega.net with any questions or comments about your personal information, your consent, your opt-in or opt-out choices, or this MPP, in general.

Your California Privacy Rights

Since 2005, California Civil Code Section 1798.83 permits our customers who are California residents to request certain information regarding our disclosure of personal information to third parties for their direct marketing purposes. We do not share user’s personal information with unaffiliated third parties for their own direct marketing purposes. For inquiries regarding our disclosure policy, please write us:

SEGA Networks Inc.
Customer Service Department
612 Howard Street
Suite 200
San Francisco, CA 94105
privacy@sega.net

 

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7. Sega’s Commitment to Data Security

 

Sega uses commercially reasonable physical, managerial, and technical safeguards to preserve the integrity and security of our systems. These safeguards include, among other things, limiting access to such data to those employees performing a legitimate business function, use of encryption and passwords, and the storage of data on secure servers or computers. These measures are also designed to protect any user information Sega may obtain, collect and/or retain as described in this MPP from unauthorized access, disclosure, use and modification. However, please be aware that, despite our best efforts, no security measures are perfect or impenetrable.

 

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8. Questions or Comments about this Mobile Privacy Policy

 

If you have questions or wish to send us comments about this Mobile Privacy Policy, please contact us at:

Sega Networks Inc.
Customer Service Department
612 Howard Street
Suite 200
San Francisco, CA 94105
privacy@sega.net
 

As aforementioned, Sega is a licensee of the ESRB’s Privacy Certified Program. If you believe that we have not responded to your privacy-related inquiry or your inquiry has not been satisfactorily addressed, please contact ESRB at https://www.esrb.org/privacy/contact.jsp, or:

 

 

ESRB

 

Attn: Privacy Certified Program
420 Lexington Avenue, Suite 2024
New York, NY 10170
privacy@esrb.org

 

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Appendix 1 - Third Party Advertising for certain SEGA Apps 

Last updated - April 25, 2016

 

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