# SEGA OF AMERICA PRIVACY POLICY

## FOR ZERO DATA TITLES

Last updated on September 9. 2021

Version - ZERO_0001, EN

## Introduction

This privacy policy explains how Sega of America,Inc. collects, uses, shares and protects your information when you use our games, as well as your rights and choices about such collection, use and sharing.

Sega of America, Inc., located at the address set forth in Section 7 “Contact Us” is the data controller for the information collected via this game.

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.

## 1. Information we collect

This title has limited data functions. The game does not send or receive any data to SEGA or any third parties. Any save games will be stored on your device, which means if you move devices or delete your game, you will need to start your game from the beginning.

If you choose to contact customer support, your communication to us will be stored (with your email address) on our customer support platform so we can reply to your message.

Regardless of your method of contact, you can ask us to delete the communication log upon resolution of your support inquiry, and we will do so.

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## 2. How we use the information we collect

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 under the relevant terms of service. We may share non-personal information about your issues with our development team to identify areas and issues we can improve in our games.

## 3. When we share information

• If our business relating to the game 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 in which you are located 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 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.

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 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 on your device by removing the game from your device, which will also delete any related files (save games). In addition, you may contact us as described in Section 7 “Your questions and how to contact us” to exercise any of your rights. If you are a California resident, please include “California Privacy Rights Request” in the first line of the description and include your name, street address, city, state, and ZIP code. 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 “Your questions and how to contact us”. 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 in our customer support platform then we will take reasonable steps to remove such information.

## 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 writing to us at:

Sega of America Inc,

6400 Oak Canyon, Suite 100

Irvine, CA 92618

USA

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

If you believe we have not responded to your inquiry or your inquiry has not been satisfactorily addressed, you may also contact the ESRB Privacy Certified at privacy@esrb.org or at https://www.esrb.org/privacy/contact.