Effective Date: [July 3, 2019]

In this Privacy Policy, "DeNA", "we", "us", or "our" means DeNA Co., Ltd. and its subsidiaries.

Your privacy is important to DeNA. We designed our Privacy Policy to cover how we collect and use your information in connection with use of our official site for Pokémon Masters ("Services"). By using our Services you agree to our collection and use of your information, including your personal information, as described in this Privacy Policy. This Privacy Policy should be read together with our Terms of Use (“Terms of Use”).

So please take a moment to learn the five W's, the How, and other important matters about the information we collect and how we use it. If you have any questions, please contact us.

Contents
  • The What

    Both non-personal information and personal information may be collected and used by us

  • The Why

    The primary objective for collection and use is to deliver and improve our Services

  • The When

    When you provide information to us, or when you use the Services

  • The How

    By providing information to us directly using the Services
    Cookies may be used, but options are available to remove/disable certain cookies by the settings on your browser
    Services-related promotions may also be used by us, but you will have the option to opt-into these

  • The Who

    We may share your information with persons who help us provide the Services, but only as necessary, and they must keep it confidential
    Except only in special circumstances, we never transfer your personal information to advertisers or marketers without your separate consent
    We do not knowingly collect personal information from children under 13

  • The Where

    In line with this Privacy Policy, your information may be processed in Japan and other countries as necessary

  • Changes to Privacy Policy

    We may change this Privacy Policy, so please check for any updates

  • Other Important Matters

    Measures are taken to safeguard information received from you, and we keep your personal information only as long as necessary
    Certain provisions of this Privacy Policy are for California residents; if you are a California resident, you should confirm if they apply to you

The What

In the course of using our Services, you may provide us, directly and indirectly, with both personal and non-personal information. Personal information is information that can be used to identify you as an individual, and might include your name, phone number, pictorial representation, email address, postal address, etc. Non-personal information is information that does not permit direct association with you. Both personal information and non-personal information may be used alone or in the aggregate with information collected from other users. Certain non-personal information would be considered a part of your personal information if it were combined with other identifiers (e.g., combining your zip or postal code with your street address) in a way that enables you to be identified. But the same pieces of information are considered non-personal information if they are taken alone or combined only with other non-personal information (e.g., your viewing preferences) provided the information cannot otherwise be linked or attributed back to you as an identifiable individual.

The Why

Our primary objective in collecting your information is to provide you with a superior and personally relevant user experience. To achieve this, your information may be used as follows or by requesting explicit consent where required by law:

  • To help us develop, deliver (in accordance with our Terms of Use), and improve our Services, including the following aspects of our Services:
    • messaging and other communication to and with users
    • the creation, updating, accessing, and maintaining of lists of friends or contacts
    • social communication and user-interactive features
    • where consent is necessary, the delivery and targeting of advertising in the Services
    • tracking of advertisement fulfillment metrics in the Services
    • recommending Services-related products or services of interest directly to you
  • For market research purposes that support our efforts to deliver a more valuable service to our community of users,
    To contact you with announcements, newsletters, and promotional materials related to our Services or to offer you opportunities to participate in surveys, contests, or sweepstakes (any of these a "Promotion") via our Services.
  • To provide end-user support.
  • To prevent and take measures against fraud, illegal activities, infringement of our rights or interests, or breaches of our Terms of Use and this Privacy Policy.
  • To send important notices, such as changes to our Terms of Use, this Privacy Policy, or other Services-specific policies. Because this information is important to your interactions with us, you may not opt out of receiving these communications.
  • To audit and analyze data for technical administration, to improve our Services, and for end-user communications.
The When

Your information is collected by us when you directly interact with our Services and otherwise through use of our Services via your device you use to access or use our Services (“Device”).

When you use our Services, we collect information related to your Device as described in "The How" section below.

If you choose to participate in a Promotion, we may request that you provide us with personal information such as your email address or postal address in order to administer your participation in the Promotion.

The How

As already mentioned, we may collect information from you when you directly interact with our Services and otherwise through your access to or use of our Services.

Direct interaction includes such actions as providing an email address. You specifically agree that we shall have the right, but not the obligation, to collect and store the information referred to in this paragraph.

We may also collect your information from third parties who provide it to us, including other users of our Services.

As is standard practice, we do use "cookies" in connection with the Services. A cookie is a small string of text placed on your Device. In addition to strictly necessary cookies that enable us to provide our Services, we may use both performance-gauging and functionality-gauging cookies. Performance-gauging cookies reveal how you use the Services, for instance, which content is the most popular, how much time users are spending there, and what advertising is relevant to you, which helps us provide an optimized experience (we may engage third parties to carry out this analysis, and they may set their own "third party" cookies--see "The Who" for more). Functionality-gauging cookies enables us to remember certain choices you make in interacting with the Services, for instance, any geographic location, language, or fonts you choose, which helps us tailor the Services to your preferences. Neither performance-gauging cookies nor functionality-gauging cookies collect information in any way that personally identifies you.

Except for cookies strictly necessary for enabling us to provide our Services, you have the option to disable cookies stored on your browser by changing the options in your browser to stop accepting cookies or to prompt you before accepting a cookie from the content you visit. If you do not accept cookies, you may not be able to view or use parts of our Services due to limited functionality. Some cookies we use may be stored using a web-browsing component other than a browser application--these cannot be disabled on your Device, but the information collected does not personally identify you, and does not permit tracking between Services.

Some of our Services, including messaging, may use "click-through URLs" linked to other content on our Services. We track this click-through data to help us determine interest in topics, Services usability, and other measures of user engagement.

In using our Services, our servers record information sent from your Device, which may include information such as cookies and language.

BY ACCESSING OUR SERVICES, YOU ARE CONSENTING TO THE USE OF COOKIES UNDER THE TERMS OF THIS PRIVACY POLICY.

The Who

Our Responsibility for Our Collections
Persons with Whom We May Share Your Information

You agree that we may share your information as follows:

  • With Third Parties for Industry Analysis and Advertising

    You agree that we may share technical information related to your Device (such as cookies), aggregated non-personal information, and anonymous information with advertisers, ad networks, and analytics analysis entities ("Ad Entities") with whom we have strategic relationships, and Ad Entities may also be permitted to collect such information via cookies and other tracking technologies. This information may be used to undertake user trend analyses, demographic profiling, and analytics, and to provide to you tailored and personalized ads and advertising (behavioural advertising). Please note, though, that some Ad Entities also act as Service Providers (defined below) for us, and in those cases we may share your information as explained below.

  • With our Service Providers

    Sharing of your information may also occur where we engage or employ service providers, vendors, or other third parties to help us provide our Services (each a "Service Provider") (e.g., improvement of our Services' features, promotion and marketing, administration, analytics, customer service, cloud storage, hosting, and other related services), to provide the Services on our behalf, or to assist us in analyzing how our Services are being used. Our Service Providers may have access to your personal information only to perform these tasks on our behalf, and they are obligated not to disclose or use your personal information for any other purpose.

  • With Certain Third Parties in Special Circumstances

    At times, we may disclose information about you to law enforcement officials or private parties as we believe necessary or appropriate to respond to claims and legal process (including subpoenas), to protect the property and rights of DeNA or a third party, to protect the safety of the public or any person, or to prevent or stop activity we may consider to be, or to pose a risk of being, illegal, unethical, or legally actionable activity.

    Under another special set of circumstances, for example, in connection with a merger, acquisition, reorganization, or sale of assets, or in the event of bankruptcy, we may sell or transfer some or all of our assets, and in this connection we may transfer all of your information, including personal information, to any successor entity.

Policy Not to Collect Personal Information from Children

We do not knowingly collect personal information from, or store personal information of, children. We will upon notice or discovery take all reasonable efforts to erase or destroy any such personal information that may have been collected or stored by us without our knowledge.

The Where

You understand and agree that we may transfer your information to and process it in Japan and other countries outside of your country of residence. Such transfer could subject the user’s personal information to foreign laws, which may provide different levels of protection than those in your home country.

Changes to Privacy Policy

We reserve the right to change, amend or modify this Privacy Policy at any time. If we change this Privacy Policy in a material way, we will give notice of that in the Services, on our website (https://dena.com/legal/), and/or by email to any email address we may have for you at that time. Your use of our Services after we have changed the Privacy Policy will apply the Privacy Policy in effect at the time your personal information is collected.

Other Important Matters
Protecting Your Information

We take your privacy very seriously and employ reasonable administrative, physical, and electronic measures to safeguard information received from you and held by us against identity theft and unauthorized access or alteration. In addition, we will take reasonable steps to assure that third parties to whom we transfer any data will provide sufficient protection of your personal information. We do not and will not, at any time, request your credit card information, your username, login password, or any national identification numbers in a non-secure or unsolicited communication (e.g., via e-mail, telephone, or mobile device). We will not keep your personal information any longer than needed for the purpose it was collected or than is necessary for legal or legitimate business purposes.

We will make any legally required disclosures of any breach of the security, confidentiality, or integrity of your unencrypted electronically stored "personal data" or "personal information" (as defined in applicable statutes on security breach notification) to you via email or conspicuous posting on our website in the most expedient time possible and without unreasonable delay, consistent with (i) the legitimate needs of law enforcement; or (ii) any measures necessary to determine the scope of the breach and restore the reasonable integrity of the data system.

Corrections and Certain Opt-Out Options

If you have any concerns with the way we collect and handle your personal information, or would like to correct or request that we delete such personal information held by us, please contact us. We will use commercially reasonable efforts to honor your request; please note, though, that at a minimum we may retain an archived copy of your records as required by law or to send necessary communications to you under this Privacy Policy. You understand that deletion of your personal information may result in you not being able to view or use portions of our Services which depend on such information.

For a Promotion you have opted into, you have the option to opt out at any time from participation in such Promotion and the receipt of any related communications by following unsubscribe instructions provided in the relevant communications, or by selecting not to receive communications from us where the relevant media service offers that option.

For more information, including possible options you may have, on the use of behavioural advertising by Ad Entities generally, see, e.g., the Digital Advertising Alliance, the Network Advertising Initiative.

Other Websites and Services

Our Services may contain links to other websites and online services or offers from third parties. For example, our Services may include offers from third party advertisers or the ability to engage in transactions with such entities. If you choose to participate in offer-linked information requests or "click on" an advertisement or another third party link, you may be directed to that third party's website or service and/or be prompted to provide personal information in connection with such activity.

The fact that we link to a third party website or service is not an endorsement or representation of our affiliation with that third party, nor is it an endorsement of such third party's privacy or information security policies or practices or their compliance with any laws. We do not exercise control over third party websites or services, and this Privacy Policy does not apply to information collected by them, including Ad Entities. These other websites or services may place their own cookies or other tracking devices on your computer or mobile device, or collect data or solicit personal information from you. Other websites and services follow different rules regarding the use or disclosure of the personal information you submit to them. We encourage you to read the privacy policies or statements of the other websites and services you use and the terms of the offers in which you participate. You agree that we are not responsible for, nor will we be liable to you or any third party for, your interaction with such third parties or the information requests initiated by such third parties or the subsequent use, treatment, or dissemination of the information you provide to them.

California Residents: Your California Privacy Rights

California law permits those of our customers who are California residents the right to request certain information regarding our disclosure of personal information to third parties for their direct marketing purposes. To make such a request, please contact us.

If you are under 18 and resident in California, you may request and obtain removal of content or information posted by you on our Services as a registered user of our Services. You may request removal by providing us via this form with (i) the user name associated with your registration; and (ii) a description sufficient to identify and locate each item of content and/or information posted on our Services by you as a registered user of our Services that you wish removed. Please note that as permitted or required by applicable law, removal does not ensure complete or comprehensive removal of the content or information posted on our Services by you as a registered user.

To the extent that any of our mobile applications of the Services collects personally identifiable information, that is done only as strictly necessary to enable us to provide those Services (see The How, above), and this cannot be disabled by "do not track" or other mechanisms available via your mobile Device's browser.

Contacting Us

If you have any questions, inquires, requests, or complaints concerning this Privacy Policy or our information collection practices, please contact us at dena@opencs.dena.jp or by post:

Attn: DeNA Customer Support Center, Shibuya Hikarie, 2-21-1 Shibuya,
Shibuya-ku, Tokyo
150-8510 JAPAN.


Privacy Policy (for the users in EU/EEA)

Effective date: [July 3, 2019]

In this Privacy Policy, "DeNA", "we", "us", or "our" means DeNA Co., Ltd.

Your privacy is important to DeNA. We designed our Privacy Policy to cover how we collect, use your information in connection with use of our official site for Pokémon Masters ("Services"). By using our Services, you agree to our collection and use of your information, including your personal information, as described in this Privacy Policy. This Privacy Policy should be read together with our Terms of Use (“Terms of Use”).

So please take a moment to learn the five W's, the How, and other important matters about the information we collect and how we use and share it. If you have any questions, please contact us.

Contents
The What and the Why

In the course of using our Services, you may provide us, directly and indirectly, with both personal and non-personal information. Personal information is information that can be used to identify you as an individual. Non-personal information is information that does not permit direct association with you. Both personal information and non-personal information may be used alone or in the aggregate with information collected from other users. Certain non-personal information would be considered a part of your personal information if it were combined with other identifiers (e.g., combining your zip or postal code with your street address) in a way that enables you to be identified. But the same pieces of information are considered non-personal information if they are taken alone or combined only with other non-personal information (e.g., your viewing preferences). provided the information cannot otherwise be linked or attributed back to you as an identifiable individual.

Some data is necessary for enabling us to provide the registration to and usage of our Services. This includes the data below.

ItemTypes of DataPurpose of use
Cookiesperformance-gauging cookies
functionality-gauging cookies

To help us develop, deliver, and improve our Services, including the following aspects of our Services:

  • messaging and other communication to and with users
  • social communication and user-interactive features
  • providing end-user support.
Basic informationLanguage
Cookiesperformance-gauging cookies
functionality-gauging cookies
To prevent and take measures against fraud, illegal activities, infringement of our rights or interests, or breaches of our Terms of Use and this Privacy Policy.
Cookiesperformance-gauging cookies
functionality-gauging cookies
To audit and analyze data for technical administration, to improve our Services, and for end-user communications
Basic InformationLanguage

In addition to the above data, we would also like to use the below data for general advertisement purposes and to inform you of our future offers and similar products.

ItemTypes of DataPurpose of use
Cookiesperformance-gauging cookies
functionality-gauging cookies
Recommending Services-related products or services of interest directly to you.
Basic InformationLanguage
Cookiesperformance-gauging cookies
functionality-gauging cookies
For market research purposes that support our efforts to deliver a more valuable service to our community of users, including using your information to contact you with announcements, newsletters, and promotional materials related to our Services or to offer you opportunities to participate in surveys, contests, or sweepstakes via our Services.
The When
Direct interaction and use of our Services

Your information is collected by us when you directly interact with our Services and otherwise through use of our Services via your Device (as described in the “How” section below).

Promotion services

If you actively choose to participate in a Promotion, we may request that you provide us with personal information such as your email address or postal address in order to administer your participation in the Promotion.

Duration of Storage

We will not keep your personal information any longer than needed for the purpose it was collected or than is necessary for legal or legitimate business purposes.

The How

As already mentioned, we may collect information from you when you directly interact with our Services and otherwise indirectly through your access to or use of our Services.

Direct interaction

Direct interaction includes such actions as providing an email address. You specifically agree that we shall have the right, but not the obligation, to collect and store the information referred to in this paragraph.

Information from Third Parties

We may also collect your information from third parties who provide it to us, including other users of our Services.

"Click-Through URLs"

Some of our Services, including messaging, may use "click-through URLs" linked to other content on our Services. We track this click-through data to help us determine interest in topics, Services usability, and other measures of user engagement.

Recording information from your Device
In using our Services, our servers record information sent from your Device, which may include information such as cookies and language.
The Who
Our Responsibility for Our Collections

While we will collect and use your information as explained in this Privacy Policy.

Persons and Entities with Whom We May Share Your Information

To the extent you have agreed in the consent form in section “The What” above, we may share your information as follows:

  • With Third Parties for Industry Analysis and Advertising

You agree that we may share technical information related to your Device (such as cookies), aggregated non-personal information, and anonymous information with advertisers, ad networks, and analytics analysis entities ("Ad Entities") with whom we have strategic relationships, and Ad Entities may also be permitted to collect such information via cookies and other tracking technologies. This information may be used to undertake user trend analyses, demographic profiling, and analytics, and to provide to you tailored and personalized ads and advertising (behavioural advertising). Please note, though, that some Ad Entities also act as Service Providers (defined below) for us, and in those cases we may share your information as explained below.

Ad Entities

  • With our Service Providers

Sharing of your information may also occur where we engage or employ service providers, vendors, or other third parties to help us provide our Services (each a "Service Provider") (e.g., improvement of our Services' features, promotion and marketing, administration, analytics, customer service, cloud storage, hosting, and other related services), to provide the Services on our behalf, or to assist us in analyzing how our Services are being used. Our Service Providers may have access to your personal information only to perform these tasks on our behalf, and they are obligated not to disclose or use your personal information for any other purpose.

  • With Certain Third Parties in Special Circumstances

At times, we may disclose information about you to law enforcement officials or private parties as we believe necessary or appropriate to respond to claims and legal process (including subpoenas), to protect the property and rights of DeNA or a third party, to protect the safety of the public or any person, or to prevent or stop activity we may consider to be, or to pose a risk of being, illegal, unethical, or legally actionable activity.

Under another special set of circumstances, for example, in connection with a merger, acquisition, reorganization, or sale of assets, or in the event of bankruptcy, we may sell or transfer some or all of our assets, and in this connection we may transfer all of your information, including personal information, to any successor entity.

Policy Not to Collect Personal Information from Children

We do not knowingly collect personal information from, or store personal information of, children. We will upon notice or discovery take all reasonable efforts to erase or destroy any such personal information that may have been collected or stored by us without our knowledge.

The Where

You understand and agree that we may transfer your information to and process it outside your country of residence, including in Japan. Such transfer could subject the user’s personal information to foreign laws, which may provide different levels of protection than those in your home country.

We do not transfer personal data to recipients outside the EU/EEA unless:

―the jurisdiction in which the recipient is located is deemed to provide an adequate level of data protection;

―there are appropriate safeguards in place (e.g. binding corporate rules; contractual arrangements with the recipient of the personal data, using, for example, the standard contractual clauses approved by the European Commission, adherence to a code of conduct or certification mechanism together with obtaining binding and enforceable commitments from the recipient) or

―a derogation or exemption applies (e.g. where an individual has explicitly consented to the proposed transfer after having been provided with all necessary information about the risks associated with the transfer).

Changes to Privacy Policy

We reserve the right to change, amend or modify this Privacy Policy at any time. If we change this Privacy Policy in a material way, we will give notice of that in the Services, on our website (https://dena.com/legal/), and/or by email to any email address we may have for you at that time. Your use of our Services after we have changed the Privacy Policy will apply the Privacy Policy in effect at the time our personal information is collected.

Other Important Matters
Your Rights

For the exercise of any of your rights mentioned below, please contact us by email at dena@opencs.dena.jp or by post at DeNA Customer Support Center, Shibuya Hikarie, 2-21-1 Shibuya, Shibuya-ku, Tokyo 150-8510.

Withdrawal of Consent

You can withdraw your consent for the collection, usage and storage of your information and data free of charge and at any time by giving us reasonable notice. Your withdrawal can be sent via mail to dena@opencs.dena.jp or by post Attn: DeNA Customer Support Center, Shibuya Hikarie, 2-21-1 Shibuya, Shibuya-ku, Tokyo 150-8510 JAPAN.

Upon receiving your request, we will inform you of the likely consequences of the withdrawal of your consent, and will cease to process your information therefrom, unless otherwise permitted or required by applicable laws and regulations. Please note that if you withdraw your consent to any or all usage of your data, depending on the nature of your request, we may not be able to provide to you our Services anymore.

Right of Information, Correction and the Right to be Forgotten

You have the right to request anytime information about the data stored by us concerning you, their source and their recipients as well as the purpose of the data processing. You further have the right of correction, and the right of deletion of the data stored with us anytime.

Right to Object

You have the right to object at any time to processing of personal data concerning yourself which are necessary for the purposes of the legitimate interests pursued by us. We will no longer process the personal data unless there are legitimate grounds for the processing which override the interests, rights and freedoms of you or for the establishment, exercise or defense of legal claims.

Right to Restriction of Processing

You have the right to obtain restriction of procession when:

(a) the accuracy of the personal data is contested by you, for a period enabling us to verify the accuracy of the personal data;

(b) the processing is unlawful and you oppose the erasure of the personal data and request the restriction of their use instead;

(c) we no longer need the personal data for the purposes of the processing, but they are required by you for the establishment, exercise or defence of legal claims;

(d) you have objected to processing your data pending the verification whether the legitimate grounds of us override those of yours.

Right to Data Portability

You have the right to receive the personal data concerning yourself, which you have provided to us, in a structured, commonly used and machine-readable format and have the right to transmit those data to another controller without hindrance from us, where:

(a) the processing is based on consent;

(b) the processing is carried out by automated means

In exercising your right to data portability, you have the right to have the personal data transmitted directly from us to another controller, where technically feasible. The exercise of the right to data portability is without prejudice to the right to erasure.

Right to Lodge a Complaint with the DPA (for EU citizens)

Without prejudice to any other administrative or judicial remedy, you have the right to lodge a complaint with a supervisory authority, in particular in the EU Member State of your habitual residence, place of work or place of the alleged infringement if you are not satisfied with our response or think we are processing your personal data not in accordance with the law.

Protecting Your Information

We take your privacy very seriously and employ reasonable administrative, physical, and electronic measures to safeguard information received from you and held by us against identity theft and unauthorized access or alteration. In addition, we will take reasonable steps to assure that third parties to whom we transfer any data will provide sufficient protection of your personal information. We do not and will not, at any time, request your credit card information, your username, login password, or any national identification numbers in a non-secure or unsolicited communication (e.g., via e-mail, telephone, or mobile device).

We will make any legally required disclosures of any breach of the security, confidentiality, or integrity of your unencrypted electronically stored "personal data" or "personal information" (as defined in applicable statutes on security breach notification) to you via email or conspicuous posting on our website in the most expedient time possible and without unreasonable delay, consistent with (i) the legitimate needs of law enforcement; or (ii) any measures necessary to determine the scope of the breach and restore the reasonable integrity of the data system.

If you have any concerns with the way we collect and handle your personal information, or would like to correct or request that we delete such personal information held by us, please contact us. We will use commercially reasonable efforts to honor your request; please note, though, that at a minimum we may retain an archived copy of your records as required by law or to send necessary communications to you under this Privacy Policy. You understand that deletion of your personal information may result in you not being able to view or use portions of our Services which depend on such information.

For more information, including possible options you may have, on the use of behavioural advertising by Ad Entities generally, see, e.g., the Digital Advertising Alliance, the Network Advertising Initiative.

Other Websites and Services

Our Services may contain links to other websites and online services or offers from third parties. For example, our Services may include offers from third party advertisers or the ability to engage in transactions with such entities. If you choose to participate in offer-linked information requests or "click on" an advertisement or another third party link, you may be directed to that third party's website or service and/or be prompted to provide personal information in connection with such activity.

The fact that we link to a third party website or service is not an endorsement or representation of our affiliation with that third party, nor is it an endorsement of such third party's privacy or information security policies or practices or their compliance with any laws. We do not exercise control over third party websites or services, and this Privacy Policy does not apply to information collected by them, including Ad Entities. These other websites or services may place their own cookies or other tracking devices on your computer or mobile device, or collect data or solicit personal information from you. Other websites and services follow different rules regarding the use or disclosure of the personal information you submit to them. We encourage you to read the privacy policies or statements of the other websites and services you use and the terms of the offers in which you participate. You agree that we are not responsible for, nor will we be liable to you or any third party for, your interaction with such third parties or the information requests initiated by such third parties or the subsequent use, treatment, or dissemination of the information you provide to them.

Contacting Us

If you have any questions, inquires, requests, or complaints concerning this Privacy Policy or our information collection practices, or wish to exercise any of your legal rights, please contact us at dena@opencs.dena.jp or by post Attn: DeNA Customer Support Center, Shibuya Hikarie, 2-21-1 Shibuya, Shibuya-ku, Tokyo 150-8510 JAPAN.

To communicate with our Data Protection Officer, please email to dpo[at]dena.com
*Please replace [at] with @.