Privacy Notice

THE POKÉMON COMPANY PRIVACY NOTICE FOR POKÉMON RUMBLE RUSH

For users outside Asia* (see the bottom of this notice for a list of countries in Asia)

INTRODUCTION

This privacy notice (Privacy Notice) sets out the ways in which we, The Pokémon Company, and its affiliates Pokémon Center Co., Ltd., The Pokémon Company International, Inc., and Pokémon Korea, Inc., collect and use your personal data (your personal information) in connection with Pokémon Rumble Rush (our App). It also explains what rights you have to access or change your personal data.

ABOUT US

  1. 2.1The Pokémon Company is a company registered in Japan, with our address as set out below.
  2. 2.2You can contact us as follows:
    The Pokémon Company International, Inc.
    Attention:
    Pokémon Rumble Rush
    Address:
    10400 NE 4th Street, Suite 2800
    Bellevue, WA 98004 USA
    Email:
    privacyquestions@pokemon.com

INFORMATION WE COLLECT ABOUT YOU

  1. 3.1Information that you provide to us.
    1. 3.1.1We will collect any information that you provide to us when you
      (a)
      access certain features or functions in our App that require personal information;
      (b)
      connect and share to a social network through our App, if you are over the age of 16 years;
      (c)
      make an inquiry, provide feedback, or make a complaint via email or our customer support site; and
      (d)
      submit correspondence to us via post, email, or our customer support site.
    2. 3.1.2The information you provide to us when you use our App will include (depending on the circumstances)
      (a)
      Identity data. Country where you are located and date, month and year of birth; and
      (b)
      Player profile data. You may also provide a username and language preferences.
  2. 3.2Information we collect about you.
    (a)
    Transactional data. We will collect information related to your purchase transactions through our App, including the date and time, the amounts charged, and other related transaction details.
    (b)
    Information contained in correspondence. We will collect any information contained in any correspondence between us. For example, if you contact us for customer support, we keep a record of that correspondence.
    (c)
    Technical data. We will also collect certain information about how you use our App and the device that you use to access our App, even where you have not created an account or logged in. This might include your geographical location, device information (such as your hardware model, operating system information, and unique device identifiers), advertising ID (in apps that display advertising), unique player identifiers such as player ID, player key, access key, the data transmitted by your browser (such as your IP address, time zone settings, access status / HTTP status code, language settings, and time zone settings referral source), information about your interactions with the App, including time- and date-stamped information such as page views, requests, number of sessions, number of downloads, users’ game progress, and gameplay-related data, length of visit to the App, keystroke logs, and similar information. This information may be collected by a third-party analytics service provider on our behalf and/or may be collected using cookies or similar technologies. For more information on cookies, please read paragraph 6 below.
    (d)
    App permissions. We may also request permission to access apps and certain features on your device. Our App may request access to GPS when you consent to our collecting geolocation data. We may also request access to your device’s photo features, if you wish to capture a screen save of the game screen in a photo album.

HOW WE USE INFORMATION ABOUT YOU AND RECIPIENTS OF YOUR INFORMATION

  1. 4.1We will use your information for the purposes listed below, either on the basis of
    (a)
    performance of your contract with us and the provision of our services to you;
    (b)
    your consent (where we request it);
    (c)
    our need to comply with a legal or regulatory obligation; or
    (d)
    our legitimate interests.
  2. 4.2We use your information on the basis of the above (see paragraph 4.1) and for our legitimate business objectives, including the following purposes:
    (a)
    To provide access to our App. To provide you with access to our App in a manner convenient and optimal and with personalized content relevant to you and to allow you to have a record of your gameplay within the App;
    (b)
    To allow you to access certain App features. To enable you to access features such as social network integration, in-App purchases, and gameplay;
    (c)
    To enable you to play with each other. We will use the information you have provided (such as your username and language settings) to enable you to play with each other;
    (d)
    To process and facilitate transactions between us. We will use your information to process transactions and payments, and to collect and recover money owed to us;
    (e)
    User and customer support. To provide customer service and support, deal with inquiries or complaints about our App, and share your information with our App developers, IT support provider, and payment services provider as necessary to provide customer support;
    (f)
    To send push notifications. To send you push notifications about your use of our App, our news, events, new App features, products, or services that we believe may interest you, provided that we have the requisite permission to do so;
    (g)
    Analysis. To use data analytics to improve our App, products/services, marketing, customer relationships, and experiences;
    (h)
    Fraud and unlawful activity detection and prevention. To protect, investigate, and deter against fraudulent, unauthorized, or illegal activity, including identity fraud; to protect the rights and property of Pokémon, our agents, our customers, and others, including to enforce our terms, policies, rules, and agreements; to protect the safety and security of any person; and/or to protect the safety and security of Pokémon’s and our partners’ Services, websites, and applications; and
    (i)
    Compliance with policies, procedures, and laws. To enable us to comply with our policies and procedures and enforce our legal rights, or to share your information with our technical and legal advisors, and to comply with laws or respond to lawful requests and legal process, including, for example, complying with a court order or subpoena.
  3. 4.3If you are in the EU and have any concerns about our processing, please refer to details of “The Rights of Users” in paragraph 9 below.

WHO WE MIGHT SHARE YOUR INFORMATION WITH

  1. 5.1In connection with the purposes and on the lawful grounds described above, we will share your personal information when relevant with third parties, such as
    (a)
    App users that you play. Other App users who you play against or play with, who are based both inside and outside the EU;
    (b)
    Our service providers. Third-party vendors, consultants, and other service providers who work for us and access your personal information to do that work, including Nintendo Co., Ltd.;
    (c)
    Corporate affiliates. The Pokémon Center Co., Ltd., The Pokémon Company International, Inc., and Pokémon Korea, Inc., based in Japan, the UK and USA, and South Korea;
    (d)
    Prospective sellers and buyers of our business. In connection with or during negotiation of any merger, financing, acquisition, bankruptcy, dissolution, transaction, or proceeding involving sale, transfer, divestiture, or disclosure of all or a portion of our business or assets; and
    (e)
    Other third parties (including professional advisers). Any other third parties (including legal or other advisors, regulatory authorities, courts, law enforcement agencies, and government agencies) based in the UK, USA, Japan, and other countries to enable us to enforce our legal rights, or to protect the rights, property, or safety of our employees, or where such disclosure may be permitted or required by law.

COOKIES AND TRACKING

  1. 6.1We and others use cookies, web beacons, device IDs, and other tracking mechanisms to ensure that you get the most out of our App. Cookies are small amounts of information in the form of text files that we store on the device you use to access our App. Cookies and other tracking mechanisms such as device IDs allow us and others to monitor your use of the software, simplify your use of our App, and help us and others associate your activities across websites, your browsers, and mobile devices you use for advertising purposes.
  2. 6.2If you do not wish to have cookies to be installed on your device, you can change the settings on your device to reject cookies. For more information about how to reject cookies using your settings, please visit http://www.aboutcookies.org. Please note that if you set your internet browser to reject cookies, you may not be able to access all of the functions of our App. Since certain opt-out preferences are also stored in a cookie on your device (such as opt-outs from advertising companies), please note that if you remove all cookies, you will need to renew your opt-out choices. Some internet browsers may transmit “Do Not Track” signals. Because uniform standards for “Do Not Track” signals have not been adopted, our App may not be aware of or process “Do Not Track” signals.
  3. 6.3Our website may contain content and links to other sites that are operated by third parties that may also operate cookies and other tracking mechanisms. We do not control these third-party sites or their tracking activities, and this Privacy Notice does not apply to them. Please consult the terms and conditions and Privacy Notice of the relevant third-party site to find out how that site collects and uses your information and to establish whether and for what purpose it uses cookies.

HOW WE LOOK AFTER YOUR INFORMATION AND HOW LONG WE KEEP IT FOR

  1. 7.1We use appropriate technological and operational security measures to protect your information against unauthorized access or unlawful use.
  2. 7.2We will retain your information for as long as is appropriate to provide you with the services that you have requested from us or for as long as we reasonably require to retain the information for our lawful business purposes, such as for legal compliance and enforcement purposes, and for resolving disputes. Actual retention periods depend on a variety of factors such as the type of product, the type and sensitivity of the data, business needs, customer expectations and needs, the types of available user controls, and the form in which the data is stored.

INTERNATIONAL TRANSFERS OF YOUR INFORMATION

  1. 8.1Our company is located in Japan, and the personal information that we collect from you will predominantly be stored in Ireland, Japan, and the USA. This will involve a transfer of data outside the EEA.
  2. 8.2Whenever we transfer your personal data from inside the EEA out of the EEA, to a country that has not been determined by the European Commission to have an adequate level of data protection, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following transfer solutions is implemented:

    Where we use certain service providers, we may use specific contracts approved by the European Commission that give personal data the same protection it has in Europe. For further details, see Standard Contractual Clauses (SCC): Standard contractual clauses for data transfers between EU and non-EU countries; and

    (a)
    Where we use providers based in the USA, we may transfer data to them if they are part of the Privacy Shield, which requires them to provide similar protection to personal data shared between Europe and the USA. For further details, see European Commission: EU-US Privacy Shield.
  3. 8.3Please contact us using the contact details at the top of this Privacy Notice if you want further information on the specific mechanism used by us when transferring your personal data out of the EEA.

THE RIGHTS OF USERS

  1. 9.1You have certain rights in respect of the information that we hold about you, including
    (a)
    the right to be informed of the ways in which we use your information, as we seek to do in this Privacy Notice;
    (b)
    the right to ask us not to process your personal data for marketing purposes;
    (c)
    the right to request access and receive a copy of any information we hold about you (or request that we transfer this to another service provider) in a structured, commonly used, machine-readable format, under certain circumstances;
    (d)
    the right to request that we correct or rectify any information that we hold about you that is out of date or incorrect;
    (e)
    in certain circumstances, the right to ask us to limit and cease processing information about you, including the right to object to our using your information on the basis of our legitimate interests;
    (f)
    the right to lodge a complaint about us with the UK Information Commissioner’s Office (https://ico.org.uk/) or the relevant authority in your country of work or residence; and
    (g)
    the right to withdraw your consent for our use of your information in reliance of your consent, which you can do by contacting us using any of the details at the top of this Privacy Notice.

    Please note that we may need to retain certain information for our own record-keeping and research purposes. We may also need to send you service-related communications relating to your website user account even when you have requested not to receive marketing communications. Where there may be exceptions to these rights in certain circumstances, and where you cannot exercise a right due to an exception, we will provide that explanation.

  2. 9.2You may exercise your rights above by contacting us using the details in paragraph 2 of this Privacy Notice or, to stop receiving push notifications, you can update your preferences in your device settings.

THIRD-PARTY LINKS

Our App may include links to third-party websites, plug-ins, and apps. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites, plug-ins, and apps and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy notice of every third party you visit.

WHAT TYPES OF INFORMATION DO WE COLLECT ABOUT CHILDREN?

  1. 11.1If a user has indicated that they are a child when trying to use our App, we will direct the child to a different experience within our App that lets a child use our services much like any other user but that does not allow any additional personal information (as defined under COPPA) to be collected.
  2. 11.2We collect only a subset of the personal information above when a user identifies themselves as a child, including username and unique identifiers. Children can use our App, view content, and enjoy many features without collection of any personal information (as defined under COPPA).

DATA PROTECTION OFFICER

If you wish to contact our Data Protection Officer, please use the following details:

  1. The Pokémon Company
    Attention:
    Data Protection Officer
    Address:
    Roppongi Hills Mori Tower 8F
    6-10-1 Roppongi, Minato-ku

CHANGES TO THIS PRIVACY NOTICE AND YOUR DUTY TO INFORM US OF CHANGES

We may amend this Privacy Notice at any time by changing the last updated date. If we make material changes to how we collect, use, or share your personal information, we will describe the changes, and, if required by law, seek your consent for such changes.

It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us by updating your profile account information or contacting us via the contact details at the top of this Privacy Notice. This Privacy Notice is effective on May 8, 2019. This Privacy Notice was updated on May 8, 2019.

SUPPLEMENTAL CALIFORNIA PRIVACY RIGHTS

Last updated [December 23, 2019]
Effective January 1, 2020

This section provides you with additional disclosures required under California law, and should be reviewed in conjunction with the Services’ general Privacy Notice before using the App (“Services”).

  1. 1If you are a California consumer whose personal information is collected through the Services (“customer”), the California Consumer Privacy Act (“CCPA”) provides you with certain rights in respect to that personal information. In particular, you have a right to request that companies provide you with the following information:
    (a)
    The categories and specific pieces of personal information we have collected about you.
    (b)
    The categories or sources from which we collect personal information.
    (c)
    The purposes for collecting and using personal information.
    (d)
    The categories of third-parties with which we share personal information.
    (e)
    The categories of personal information disclosed about you for a business purpose

    You also have a right to request that we delete personal information under certain circumstances, subject to a number of exceptions. Additionally, you have a right not to be discriminated against for exercising any of these rights.

  2. 2You may exercise your rights above by contacting us using the details provided in this supplemental California Privacy Notice. If you submit a request, we will require you to verify your identity where, if feasible, we may match your identification information with personal information we have about you, depending on the type of request made and verification measures proportional to the risk of the personal information involved with the request(s). There is no reasonable method by which we can verify your identity to the degree of certainty required by law for certain pieces of personal information, for example: unique identifiers such as cookie IDs, device ID, and IP address (where that information is not held by us in connection with directly identifiable information). There may be exceptions to these rights in certain circumstances, and where you cannot exercise a right due to an exception, Pokémon will provide that information. Pokémon will use reasonable efforts to fulfil your request within the response times of the applicable laws.
  3. 3Pokémon does not sell your personal information as defined by the CCPA and has not done so in the past 12 months.
  4. 4In addition to the purpose in which your personal information is shared with other third parties (including professional advisers) in the “Who we might share your information with” or “When we will disclose your information” section of the applicable Service’s general Privacy Notice, these purposes include sharing for business purposes that require access to our systems that hold personal information (such as supplying cloud data storage, maintaining the security of our systems, and providing customer support). In the past 12 months, we have disclosed to vendors all of the categories of personal information described in the “Information we collect about you” or “What information may be collected during your use of the App” section of the applicable Service’s general Privacy Notice.
  5. 5California Civil Code Section 1798.83 permits customers who are California residents to request certain information regarding disclosure of personal information to third parties for their own direct marketing purposes. We do not share our customers' personal information with unaffiliated third parties for their own direct marketing purposes without your consent. For inquiries about our disclosure policy, please contact us at using the details provided in this supplemental California Privacy Notice.
  6. 6If you are a California resident under the age of 18, and a registered user of any Services where this supplemental California Privacy Notice is posted, you may request and obtain removal of content or information you have publicly posted. To make such a request, please contact us with a detailed description of the specific content or information using the details provided in this supplemental California Privacy Notice. Please be aware that such a request does not ensure complete or comprehensive removal of the content or information you have posted, and that there may be circumstances in which the law does not require or allow removal even if requested.
  7. 7You can contact us as follows:
    1. The Pokémon Company International, Inc.
      10400 NE 4th Street, Suite 2800
      Bellevue, WA 98004 USA
      privacyquestions@pokemon.com
      *please include name of App