Last updated on September 14, 2021 

Sega of America, Inc. collects information about you when you use our games for Apple Arcade ("Games for Apple Arcade"). This privacy policy explains how we collect, use, share and protect your information when you use our Games for Apple Arcade, as well as your rights and choices about such collection, use and sharing.  

By using our Games for Apple Arcade you acknowledge that you have read and understand the terms of this privacy policy, including how we use personal information. Sega of America, Inc., located at the address set forth in Section 7 “Contact Us” is the data controller for the information collected via our Games for Apple Arcade. 

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.  

The privacy policy may be revised periodically, and any such revisions will be reflected by the “Effective Date” above. Please revisit this page to stay aware of any changes. If we make material changes to this privacy policy, we will provide you with additional notice of such changes by providing alerts within our Games for Apple Arcade.  

1. Information we collect

We collect limited information about you in our Games for Apple Arcade. We collect: 

(a) Game Profile Information 

During your gameplay experience, the Game for Apple Arcade will generate non-personal information about your Game for Apple Arcade experience. This information cannot be used by us to identify you. This information is stored locally on your device and may also be saved to Apple’s servers in accordance with terms governing your relationship with Apple. This information will not be transferred to our servers without your permission. We call this your “Game Profile”.  

(b) Email address for customer support 

If you choose to contact customer support, your communication to us will be sent via email. Our customer support platform will store your email address so we can reply to your message. We will delete the communication log within 30 days of completion of your customer support enquiry.  

(c) Game Analytics 

With your permission, we will collect anonymous data about your gaming experience. This data will be game event data – for example, your progression through the game, how long you play the game etc. You will be asked permission before any data is sent to our servers, and this data will be anonymous.  

2. How we use the information we collect 

We use the information we collect for the following purposes: 

(a) Game Profile Information 

Your Game Profile is required to record your performance through the Game for Apple Arcade. The Game Profile includes information such as the characters you have unlocked, the levels you have played and the last time you played the Game for Apple Arcade. 

If you choose to play a Game for Apple Arcade in multiplayer mode, your Game Profile will be copied to our servers. We use this Game Profile on our server to: 

• Ensure you are matched with similarly skilled players in your geographic region 

• Update your Game Profile with your multiplayer wins/losses/rewards 

• Transfer your Game Profile to your other supported devices (our Games for Apple Arcade can be played on iPhone, iPad, AppleTV and macOS devices) 

If your Game Profile is saved to our game servers, it will be connected to you by your Game Center ID. The Game Center ID we use is unique to the specific Game for Apple Arcade and cannot be used to record your play across other games or products. 

Your Game Profile may be saved Apple’s servers to transfer your Game Profile to your other supported devices.  

(b) Customer Support 

We use personal information you provide via customer support requests to reply to your questions or queries, to provide customer support and resolve problems relating to any of our Games for Apple Arcade under the relevant terms of service. We may share non-personal information about your issues with the Games for Apple Arcade with our development team to identify areas and issues we can improve in our Games for Apple Arcade. 

(c) Game Analytics 

The analytics data we collect will be used to help us improve the game. Using the data, we will be able to see how users experience the game. It will highlight any areas that cause players friction and will allow us to make better decisions about the changes we make to the game.  

3. When we share information 

In delivering the Games for Apple Arcade to you, we may share your personal information with: 

• Companies within the SEGA group (which means our subsidiaries and affiliates, our ultimate holding company and its subsidiaries and affiliates) who act for us for the purposes set out in this policy. 
• Third parties with whom we share your information in order to undertake various activities or services on our behalf in supporting the Games for Apple Arcade, including authorizing our third party partner’s subprocessors to process relevant data only in accordance with our instructions as needed to provide the respective service. These include hosting providers for online services and customer support software providers for helping us manage customer support. 
• If our business relating to the Games for Apple Arcade enters into a joint venture, purchases or is sold to or merged with another business entity, your information may be disclosed or transferred to the target company, or new business partners or owners or their advisors.  
• We may use the information that you provide if we are under a duty to disclose or share your information in order to comply with (and/or where we believe we are under a duty to comply with) any legal obligation; or to enforce the relevant terms of service and any other agreement; or to protect our rights or the rights of third parties. This includes exchanging information with other companies and organizations such as credit agencies, law enforcement or government bodies or the courts in connection with a criminal investigation, suspected illegal activity, fraud prevention and detection or in legal proceedings. 

Personal information may be transferred to other countries where we or our service providers maintain operations. These countries may not have equivalent data protection laws to the country from where you access the Games for Apple Arcade or, in the case of transfers subject to European law, may not be subject to an adequacy decision by the European Commission (EC). An adequacy decision is a decision taken by the EC establishing that a third country provides a comparable level of protection of personal data to that in the EU, through its domestic law or its international commitments. When we transfer personal information, we will seek to take account of any applicable legal obligations relevant to personal information transfers. In the case of transfers of personal information out of the European Economic Area, we will, in the absence of an EC adequacy decision relevant to the destination country, seek to rely on appropriate safeguards such as a valid Privacy Shield certification (in the case of a data transfer to a Privacy Shield certified US recipient - https://www.privacyshield.gov/welcome) or enter into appropriate EC approved standard contractual clauses relevant to personal data transfers between data controllers or between a data controller and a data processor, (see http://ec.europa.eu/justice/data-protection/international-transfers/transfer/index_en.htm). 

4. Security and data retention 

We take reasonable physical, technical and organizational measures, to protect your information from unauthorized access and against unlawful processing, accidental loss, destruction and damage.  

Your personal information will be retained by us for the duration of your use or access to our Games for Apple Arcade 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 the relevant terms of service, any “sun-setting” requirements or to identify, issue or resolve legal proceedings. Outside of any legal proceedings, any information stored on our servers will be deleted after 330 days of inactivity.  

We may retain a record of your stated objection to the processing of your data, 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, when you withdraw consent (as applicable) or at your request. 

5. Your choices and rights 

You have options and choices over how we use your information. We provide you with tools to access and update specific information relating to your use of the Games for Apple Arcade at any time. We respect the rights you may have under applicable law to request access to your personal information 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 information, 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. We do not verify the correctness of your personal information.  

You may delete your Game Profile stored on our servers by using the button available in the Options menu to delete your data. In addition, you may contact us as described in Section 7 “Contact Us” to exercise any of your rights. If you remain unhappy with a response you receive, and are in the European Union, 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 inquiries regarding our disclosure policy, please contact us as described below in Section 7 “Contact Us”. Requests must include “California Privacy Rights Request” in the first line of the description and include your name, street address, city, state, and ZIP code. In addition, if you believe that we have not responded to your privacy-related inquiry or your inquiry has not been satisfactorily addressed, please contact Sega of America, Inc.’s Data Protection Officer (dataprivacy@segaamerica.com).  

6. Children’s information 

If we learn that we have collected personal information of users under the age of 13 or other applicable age of consent, other than persistent identifiers for support of the internal operations of the Games for Apple Arcade (in the U.S.) and/or for our legitimate interests (outside the U.S.), then we will take reasonable steps to remove such information.  

We may collect non-personally identifiable information from children, such as country settings and language settings to ensure compliance with the applicable law for the specified country. If you believe that we may have unintentionally collected personal information about your child, you may contact us using the details provided below. 

7. Your questions and how to contact us 

If you have any questions or comments about this 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 

USA 

You can also contact our Data Protection Officer at dataprivacy@segaamerica.com. 

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