It is important that users of Bandai Namco Entertainment America Inc.’s (“BNEA”, “we”, or “us”) Online Services (defined in the policy introduction) read this Privacy Policy in full. It explains who BNEA is, how and why BNEA collects Personal Data (defined under A3) from users, how and why it will be processed by BNEA, and BNEA’s commitment to protecting user information.
However, if you do not have time to read it in full, we have summarized the key points for you in our 'speed read' section below.
- BNEA is a data controller for user Personal Data. This means BNEA makes decisions about how it uses user Personal Data (defined under A3).
- BNEA processes (i.e. handles) user Personal Data to provide its products and services. BNEA will only process Personal Data in accordance with the relevant data privacy laws. BNEA will only process user Personal Data where it has a legal basis for doing so.
- BNEA may disclose user Personal Data to third party vendors, including payment processors and data analysts, to enable the efficient and secure provision of products and services. Except as explained in this Privacy Policy, BNEA will not disclose Personal Data to third parties, unless required to do so by law.
- BNEA will keep your Personal Data for as long as BNEA needs such Personal Data. How long BNEA needs Personal Data depends on what BNEA is using it for, whether that is to provide the Online Services to you, for BNEA’s own legitimate interests (described below), or so that BNEA can comply with applicable law. BNEA will actively review the information it holds and when there is no longer a customer relationship, legal or business need for BNEA to hold such Personal Data, BNEA will either delete such Personal Data securely or in some cases anonymize it.
- BNEA may transfer Personal Data to a recipient located outside of the user's resident country. For example, to BNEA’s main operations in the United States. If BNEA does this, BNEA will ensure that the transfer mechanism provides an adequate level of protection and complies with applicable law.
Users of the Online Services have important rights under laws aimed at protecting their Personal Data. This policy sets out these rights and how a user can exercise them. For more information, please see the section titled "Q13: What Data Privacy Rights do Users Have and How do They Exercise Them?" of this Privacy Policy. Where a user is in the UK or EU, users also have the right to make a complaint to their local data protection regulator. For more information, please see Q13.
Introduction:
BNEA respects the privacy of users of its products and services and has adopted the following Online Services Privacy Policy (the “Privacy Policy”) in furtherance of that commitment.
As described below, this Privacy Policy applies to each BNEA-operated game, website (including its webstore), forum, or other online product or service operated by BNEA where it is displayed or referenced (such as through an embedded hyperlink) (collectively, the “Online Services”), including with respect to the data collected from or provided by any user, or any user’s device, that accesses such Online Services. However, data collected through certain BNEA products or services may be subject to a different product- or service-specific privacy policy which can be accessed through such product or service and/or at: https://www.bandainamcoent.com/legal.
Any questions, comments, or concerns regarding this Privacy Policy or BNEA’s privacy practices, can be sent to privacy@bandainamcoent.com. A full list of contact details can be found at the end of this Privacy Policy.
TABLE OF CONTENTS
Q1: Why Does BNEA Have This Privacy Policy?
Q2: How Do BNEA’s Online Services Collect Information From Users And User Devices?
Q3: What Information Is Collected by BNEA Under This Privacy Policy?
Q4: What Information Is NOT Covered By This Privacy Policy?
Q5: How Does BNEA Use Information Covered By This Privacy Policy?
Q6: Where Does BNEA Store Personal Data Covered By This Privacy Policy?
Q7: How Long Does BNEA Retain Information Covered By This Privacy Policy?
Q8: To Whom Does BNEA Disclose Information Covered By This Privacy Policy?
Q9: Do Third Parties Collect Information Through BNEA’s Online Services?
Q10: What Security Measures Does BNEA Take To Safeguard Users’ Personal Data?
Q11: How Will Users Know If BNEA Changes This Privacy Policy?
Q12: Does BNEA Collect Information From Or About Children?
Q13: What Data Privacy Rights do Users Have and How do They Exercise Them?
Q14: Does BNEA Use Automated Decision Making?
Q15: How can Users Contact BNEA?
Q1: Why Does BNEA Have This Privacy Policy?
A1: BNEA’s mission is to inspire people around the world, to help them enjoy their time to the fullest, and to create “Fun For All Into The Future.” Allowing users to have confidence in BNEA’s privacy practices is essential to BNEA’s aspirations and success. To demonstrate BNEA’s concern for user privacy, BNEA has developed this Privacy Policy, which tells users – in simple, plain language – how BNEA collects, stores, uses, and discloses user data.
Q2: How Do BNEA’s Online Services Collect Information From Users And User Devices?
A2: BNEA’s Online Services may collect information from users and users’ devices, as follows:
- User Disclosure: Certain Online Services may enable, request, or require users to disclose certain information including by:
- Creating or logging into their Online Services account;
- Signing up for newsletter(s);
- Authorizing a third party, affiliate, or related company to disclose information to BNEA;
- Purchasing and receiving shipment of goods or services through the Online Services;
- Confirming age or date of birth;
- Participating in polls, surveys, questionnaires, contests, sweepstakes, events, or other promotions offered through the Online Services; or
- Submitting a request for customer support through the Online Services.
- Information Automatically Collected When You Use the Online Services: Certain Online Services may automatically collect certain information such as user activity records and device information, including when you play one of BNEA’s games or interact with a website.
- Information Received from Affiliates and Related Companies: BNEA may also be given access to certain information that affiliates and related companies have collected from a user or a user’s device, through use of such affiliate or related company’s account systems, products, websites, applications, or other services. For instance, if you log into an Online Service via Bandai Namco ID, BNEA will have access to certain information from that platform. In the event BNEA is given access to such information, BNEA’s access to and use of such information will be subject to and consistent with the privacy policies of such affiliate or related company and this Privacy Policy.
- Information Received from Third Parties: BNEA may also be given access to certain information third parties have collected from a user or a user’s device, through use of such third party’s services, games, websites, applications, or other services. In the event BNEA is given access to such information, BNEA’s access to and use of such information will be subject to and consistent with the privacy policies of the third party responsible for initially collecting it. Please note: BNEA cannot prevent third party advertisers from obtaining information about users from publicly available sources (online profiles, social media, etc.)
- Information Collected When You interact with Advertisements on the Online Services or those of BNEA’s Partners: BNEA may also collect information from a user or a user’s device when it shows you an advertisement.
Q3: What Information is Collected by BNEA Under This Privacy Policy?
A3: BNEA will collect Personal Data when a user uses one of BNEA's Online Services. “Personally-identifiable information” (or “Personal Data”) means information which could be used to identify an individual either on its own or when combined with other information. This section describes what Personal Data is collected and how BNEA collects it. The Personal Data in this section may be used for various purposes described under section A5 below under Q5 "How Does BNEA Use Information Covered By This Privacy Policy".
- First & Last Name: When provided to BNEA, this Personal Data may be stored with the user’s Online Services account information and may be accessed and updated by such user by logging into their Online Services account.
- Email Address: When provided to BNEA, this Personal Data may be stored with the user’s Online Services account information and may be updated by the user by logging into their Online Services account.
- Mailing Address: When provided to BNEA, this Personal Data may be stored with the user’s Online Services account information and may be updated by the user by logging into their Online Services account.
- Password, Security Questions & Answers: When provided to BNEA, this Personal Data may be stored with the user’s Online Services account information and may be updated by the user by logging into their Online Services account. This Personal Data will only be used to authenticate a user’s identity before granting anyone access to such user’s Online Services account.
- Profile Information: Certain Online Services will create profiles based upon your preferences, characteristics, behavior, and other information from your use of the Services.
- User Activity Records: Certain Online Services may automatically create records about user activities within such Online Services, such as dates and logs of certain user activities within such Online Services, game play information, and when certain legal terms were presented to and accepted by a user.
- Order Number: When a user purchases a product or products through the Online Services that order will be automatically assigned a unique alphanumeric identifier that is generated by or on behalf of BNEA and does not contain any Personal Data of such user (“Order Number”). That Order Number is then used to reference such user’s transaction in other records created or maintained by BNEA and/or third-party service providers to avoid unnecessary sharing of such user’s Personal Data into records that cannot easily be deleted from or modified.
- Transaction History: When a user purchases a product or products through the Online Services certain Online Services will automatically create records about a user’s transaction, such as the type of payment method, products and services purchased, and when the transaction occurred (“Transaction History”).
- User Device Information: Certain Online Services may automatically collect information about the device through which a user accesses such Online Services, which may include: (i) the device’s operating system (e.g., Windows, Mac, etc.) and version; (ii) browser type (e.g. Safari, Chrome, etc.) and version; (iii) network connection type; and (iv) other similar device information.
- User Age or Data of Birth: Certain Online Services may allow (or, in some cases, require) a user to disclose their age or date of birth. This information is used by BNEA to confirm such user meets the minimum age requirements applicable to the Online Service such user is then attempting to access.
- Region Information: Certain Online Services may ask a user to disclose, or may automatically detect the country, state, province, or region in which such user’s device is located.
- Usernames: Certain Online Services may allow a user to choose nicknames, character names, or usernames that will be used to identify that user to other users of BNEA’s Online Service(s). When provided to BNEA, such information may be stored with the user’s Online Services account information and may be updated by the user by logging into their Online Services account. However, unlike other forms of Personal Data collected under this Privacy Policy, BNEA collects this information from users for the purpose of displaying this information to other users of the same Online Service(s) and, in some cases, making such information available to the general public. Accordingly, users should not use their real name, the real name of any person, or any other Personal Data when creating usernames.
- Device/Network Identifiers: Certain Online Services may automatically collect device and/or network identifiers from a user’s device accessing such Online Services, which may include resettable identifiers (e.g., a user device’s IP address, etc.) and non-resettable identifiers (e.g., MAC Address, etc.) (collectively, “Device/Network IDs”).
- Pseudonymous Identifiers: When a user creates a BNEA Online Services account that account may be assigned a unique alphanumeric identifier that is generated by BNEA and does not contain any Personal Data of such user (each, a “Pseudonymous ID”). That Pseudonymous ID is then used to reference such user’s account in other records created or maintained by BNEA and/or third party service providers to avoid unnecessary propagation of such user’s Personal Data into records that cannot easily be deleted from or modified.
- Information related to Cookies and Other Tracking Technologies: BNEA and its advertising partners and partners who serve content on our Online Services use cookies or similar technologies. A cookie is a small piece of data (text file) that a website – when visited by a user – asks the user’s browser to store on the user’s device to remember information about that user, such as his or her language preference or login information. Those cookies are set by BNEA and generally referred to as “first party cookies.” BNEA also uses third party cookies – which are cookies from a domain different than the domain of the website a user is visiting – for user in connection with BNEA’s advertising and marketing efforts. More specifically, BNEA uses cookies and other tracking technologies for the following purposes:
- Assisting users in navigation.
- Assisting in registration to BNEA’s events, login, and to enable users to provide feedback.
- Analyzing use of BNEA’s products and services.
- Assisting with BNEA’s promotional and marketing efforts (including behavioral advertising).
Where cookies are used for Online Services, a cookie banner will be displayed and contain a detailed list of applicable cookies, which has been generated by an automated third-party scanning tool and verified by BNEA to maintain a list that is as accurate as possible. Cookies are classified in the following categories:
- Strictly Necessary Cookies.
- Performance Cookies.
- Functional Cookies.
- Targeting Cookies.
Where cookies are used for Online Services, users can opt-out of each cookie category (except strictly necessary cookies) by clicking on the “Cookie Settings” in the cookie banner.
In addition, downloading, installing, or accessing one of BNEA’s games may install or place various tracking technologies on such user device (including cookies, web beacons, pixel tags, log files, etc.). These tracking technologies may assist users in navigating or progressing through the game, record user’s settings and selections and logging user progress within the game, and enable users to provide feedback or request customer support from BNEA. These cookies are necessary for the game to function and cannot be switched off in BNEA’s systems.
- Personal Data Linked to Non-Personal Data & “Anonymized” Personal Data: In the event BNEA directly links or associates any Non-Personal Data with any Personal Data relating to a user (e.g., in an Online Services account or profile), BNEA will treat such Non-Personal Data as Personal Data. Conversely, any user information that BNEA collects from a user or user device (including Non-Personal Data that has been directly linked or associates with Personal Data), but is then aggregated, anonymized, or “hashed” in a manner that reasonably prevents any recipient from using such information to individually identify, locate, or contact the user to whom such Personal Data once related, will be treated as Non-Personal Data.
- Categories of Personal Data Collected under the California Consumer Privacy Act and the California Privacy Rights Act (the “California Privacy Laws”): California Privacy Laws require BNEA to disclose the categories of Personal Data that BNEA collects and has collected. BNEA collects and has collected withe following categories of Personal Data as listed in the California Privacy Laws within the preceding twelve (12) months:
- Identifiers, such as real name, alias, postal address, unique personal identifier, contact information, IP address, email address, account name, and other online identifiers;
- Personal information, as defined in the California customer records law, such as name and contact information;
- Characteristics of protected classifications under California or federal law, such as age.
- Commercial information, such as transaction information and purchase history.
- Internet or network activity information, such as browsing history and interactions with the Online Services or advertisements;
- Geolocation data, such as approximate location derived from IP address; and
- Inferences drawn from any of the Personal Information listed above to create a profile about, for example, an individual’s preferences, behavior, or characteristics.
BNEA only uses the above Personal Data for the purposes described in Section A5 and in the preceding twelve (12) months has only disclosed this Personal Data to the third parties, affiliates, service providers, and other persons or entities described in Section A8 of this Privacy Policy.
Q4: What Information Is NOT Covered By This Privacy Policy?
A4: Information collected through certain BNEA products or services, other than the Online Services, may be subject to a different product- or service-specific privacy policy which can be accessed through such product or service and/or at: https://www.bandainamcoent.com/legal.
In addition, this Privacy Policy does not cover the following information:
- Payment Information Collected from a User Directly by a Third Party (And Not by BNEA): Certain Online Services, including BNEA’s webstore and the stores operated by game platforms, may also require a user to provide their payment information, including first and last name, country, bank details, credit and/or debit card number, CVC, mailing address and other information to a third-party payment processor. Users are encouraged to check the payment providers' privacy policy for further information on how they process Personal Data.
- Social Media Public Profile Information: Certain Online Services may allow a user to link their Online Services account with one or more of the third-party social media platforms. BNEA is not responsible for how social media platforms process data and users and encourages to check the terms of the social media platforms they use and link their BNEA accounts to. When a user links their Online Services account with a third-party social media platform accounts, the third-party social media platform may provide BNEA with certain Personal Data relating to such user, pursuant to such third party social media platform’s privacy policy. Please note: Linking this information with your Online Services account does not allow BNEA to access other information in your third-party social media platform account, or post or publish information through such third-party social media platforms, on any user’s behalf. Additionally, information a user chooses to share in an open forum or format or in any other context after such user has been notified that such information will be made accessible to third parties (e.g., on a social media platform, user-generated content, etc.) is not covered by this Privacy Policy.
- Information contained in materials a user shares with BNEA for a business purpose: This Privacy Policy does not cover information submitted to BNEA for purposes other than use of the Online Services, including without limitation information submitted in the context of a current, former or potential role as a BNEA employee or for business inquiries (e.g. resumes, event sponsorships, proposals, etc.).
Q5: How Does BNEA Use Information Covered By This Privacy Policy?
A5: BNEA only collects, stores, and uses information if a user has consented to it, or to the extent it is necessary (i) for the performance of a user’s agreement with BNEA; (ii) to comply with BNEA’s legal obligations; or (iii) for the purpose of BNEA’s legitimate interests, including operating, evaluating and improving its global business.
Pursuant to applicable law, BNEA must have a legal basis to collect, store or use Personal Data. Users should also note that where BNEA relies on:
- Consent: Users may withdraw consent at any time. Where a user withdraws consent, they may lose access to certain features or services.
- Legitimate interests: BNEA has assessed whether using Personal Data is necessary for that particular purpose and balanced this against the user's interests. Where legitimate interests are used as a legal basis, a user may be able to exercise their rights to object to how BNEA uses that information. For more information of user rights see " Q13: What Data Privacy Rights do Users Have and How do They Exercise Them?" below.
Legal Basis |
Purposes: How We Use Your Information |
Performance of an Agreement with BNEA |
Provide the Online Services |
Provide and deliver the products and services a user requests, or process transactions and send related information to users |
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Register a user’s account on our Online Services and assist in the management of such account |
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Respond to a user’s comments, questions and requests and provide customer service |
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Send users technical notices, updates, security alerts and support and administrative messages |
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Legitimate Interest |
For any purpose required or authorized for BNEA to comply with its legal and regulatory obligations |
Monitor and analyze trends, usage and activities in connection with the Online Services |
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Detect, investigate and/or prevent fraudulent, unauthorized or illegal activity |
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Provide contextual advertisements |
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Monitor, analyze and develop brands on social media by using social media monitoring services |
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Consent |
Communicate with you about products, services, offers, promotions, rewards, and events offered by BNEA and others, and provide news, information and other marketing materials that we think will be of interest to you where you have provided us with your consent for us to do so. |
Process and deliver contest, sweepstake, and event entries and rewards/prizes promoted by BNEA where you have signed up for these. |
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Link or combine user data with other Online Services and with information we get from other sources to analyze service and monetization trends, create profiles of categories of users, create new games and services, and perform other analytics |
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Link or combine with information we get from BNEA’s advertising partners to help understand your needs and provide you with better in-Service personalized ads; serve advertisements that might be of interest to you; monitor and analyze trends, usage and activities in connection with the advertisements and the Online Services; creating profiles of types of Service users by combining your data with information from advertising partners |
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Creating profiles of types of users by combining user data with information from BNEA advertising partners, providing the data to our group companies, ad agencies and ad platforms to target advertisements of BNEA (and its group company) games and services to you outside of this service, and otherwise performing advertising analytics and performance metrics |
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For any other purpose for which a user has provided the information and consented to us using it for a defined purpose. |
Q6: Where Does BNEA Store Personal Data Covered By This Privacy Policy?
A6: Personal Data covered by this Privacy Policy may be stored and processed, for the purposes described herein, in the United States or any other country in which BNEA or its third party service providers operate, including through the use of cloud storage. Except as set forth herein, by using BNEA’s Online Services, each user understands that their Personal Data and Non-Personal Data may be transferred to recipients in the United States and other countries that may not offer the same level of privacy protection as the laws in such user country of residence or citizenship, regardless of such user’s location, residence, or citizenship.
Information collected by BNEA from EU or UK users under this Privacy Policy may be transferred outside the EEA or UK to, for example, BNEA's headquarters in the USA. For transfers from the EEA to countries not considered adequate by the European Commission, we have put in place adequate measures, including where appropriate, standard contractual clauses (adopted by the European Commission or UK Information Commissioner as appropriate) to protect user Personal Data.
While BNEA acknowledges that the EU – U.S. Privacy Shield Framework and the Swiss-U.S. Privacy Shield Frameworks (“Privacy Shield”) are not currently an international transfer mechanism on its own as interpreted by the European Commission, it provides some valuable standards and certifications in relation to the protection of Personal Data. As such, BNEA also complies with the EU-U.S. Privacy Shield Framework and the Swiss-U.S. Privacy Shield Frameworks as set forth by the U.S. Department of Commerce regarding the collection, use, and retention of personal information transferred from the European Union, the United Kingdom, and Switzerland to the United States in reliance on Privacy Shield. BNEA has certified to the Department of Commerce that it adheres to the Privacy Shield Principles with respect to such information. If there is any conflict between the terms in this Privacy Policy and the Privacy Shield Principles, the Privacy Shield Principles shall govern. To learn more about the Privacy Shield program, and to view our certification, please visit https://www.privacyshield.gov/. BNEA is responsible for the processing of Personal Data it receives, under each Privacy Shield Framework, and subsequently transfers to a third party acting as an agent on its behalf. BNEA complies with the Privacy Shield Principles for all onward transfers of personal data from the EU and Switzerland, including the onward transfer liability provisions. With respect to Personal Data received or transferred pursuant to the Privacy Shield Frameworks, BNEA is subject to the regulatory enforcement powers of the U.S. Federal Trade Commission.
Q7: How Long Does BNEA Retain Information Covered By This Privacy Policy?
A7: Information covered under this Privacy Policy will be retained by BNEA for as long as needed or permitted considering the purpose(s) for which it was obtained.
BNEA uses the following criteria to determine the retention periods:
- The length of time a user has an active relationship with BNEA and in which BNEA provides the Online Services to such user. For example, BNEA will retain Personal Data on an account for as long as a user maintains an account with BNEA.
- The length of time that it is necessary to hold that Personal Data in connection with purposes set out in this policy where BNEA has a valid legal basis.
- Whether BNEA has a legal or business obligation to retain such information.
- Whether BNEA retains some Personal Data to protect itself against legal claims or to continue to process Personal Data in relation to any ongoing legal claim.
When deciding the duration that BNEA retains Personal Data it will take into account:
- The applicable limitation period under applicable law (i.e. any period during which any person could bring a legal claim against BNEA in connection with a user’s Personal Data, or to which such Personal Data may be relevant); or
- an additional reasonable period following the end of such applicable limitation period.
For any queries about how long BNEA retains Personal Data, users should contact BNEA using the contact details at the end of this Privacy Policy.
Q8: To Whom Does BNEA Disclose Information Covered By This Privacy Policy?
A8: BNEA will not disclose to third parties any Personal Data BNEA collects from a user under this Privacy Policy, including for such third party’s own direct marketing purposes, unless a user affirmatively consents to such use. However, BNEA may disclose some information to third parties where it is necessary and where BNEA has a valid legal basis for the following purposes:
- Other Users: Other users if you choose to participate in the interactive areas of the Online Services, such as multiplayer, chat, or other sharing features. Please note: Users should refrain from creating usernames containing the real name of any person or any other Personal Data.
- Third Party Service Providers and Contractors: Third party service providers and contractors engaged by BNEA to perform services on BNEA’s behalf, such as game developers, product delivery vendors, contest or sweepstakes administration or fulfillment, surveys, payment processing, advertising campaign optimization, email management providers, network operations, customer support, and data management. These third-party service providers are required to maintain the confidentiality of any Personal Data disclosed to them and are prohibited from disclosing or using such Personal Data other than to perform specific task(s) for which they have been engaged by BNEA.
- BNEA-Affiliated Companies: BNEA’s subsidiaries, parent company, or other affiliated entities. BNEA may disclose information to these affiliated entities to identify and better understand the needs and interests of BNEA’s consumers, throughout the world, to improve BNEA’s products based such needs and interests, and market BNEA’s products and services using local resources, tailored to such needs and interests.
- A Successor or Acquiring Third Party: If BNEA is bought or acquired by a third party (either fully or partially), merged with a third party, experiences a reorganization, bankruptcy, or other similar event, or in the event BNEA conveys to a third party its right to offer or perform a particular Online Service, information collected by BNEA under this Privacy Policy may be disclosed to such third party, subject to the notification procedures set forth in Section A11, below.
- A Court, Government Agency, or Litigant: Only as permitted or required by law, or when BNEA believes in good faith that it is necessary: (i) to protect the safety or security of BNEA, its BNEA-Affiliated Companies, employees, contractors, users, or the property of any of the foregoing; or (ii) to enforce BNEA’s end user license agreement, terms of service, or its community event rules.
Q9: Do Third Parties Collect Information Through BNEA’s Online Services?
A9: BNEA may, from time to time, where it has a legal basis to do so, give certain third-party service providers limited, but direct, access to a user or a user’s device through certain BNEA Online Services, which may enable them to interact with and collect information from such user through such user’s interaction with such third party’s services. For example, BNEA may allow third party service providers to provide analytics services on its behalf and to serve advertisements within the Online Services. These entities may use technologies to automatically collect information about a user’s device and their use of the Online Services, including IP address, device ID, time spent on pages within our Online Services, and links clicked within the Online Services (as described in Section A3). This information may be used by us and others to, among other things, maintain, improve, and analyze the functioning of our Online Services and deliver contextual or targeted advertising that may be of interest to a user. The use of user information by these third parties is covered by their respective privacy policies, and BNEA does not control and is not responsible for the privacy practices of third parties.
Q10: What Security Measures Does BNEA Take To Safeguard Users’ Personal Data?
A10: The security of user Personal Data is important to BNEA. BNEA follows accepted standards to protect the Personal Data collected from users of its Online Services, both during transmission and after it is received. In addition, BNEA endeavors to ensure that user Personal Data is stored only for as long as necessary to fulfill the purpose(s) for which such information was collected and is deleted from BNEA’s records, once such purpose(s) have been fulfilled (as further described in Section A7).
Q11: How Will Users Know If BNEA Changes This Privacy Policy?
A11: BNEA may amend this Privacy Policy at any time. If BNEA makes any material changes in how BNEA collects, uses, or discloses Personal Data, BNEA will prominently post notice of the changes within the applicable Online Services or contact users by email (at the email address, if any, associated with such users’ Online Service accounts) prior to the change becoming effective. Any material changes to this Privacy Policy will be effective 30 days after BNEA’s posting of such changes within the Online Services or 14 days after advance notice, if sent by email. Please note: It is each user’s responsibility to keep their BNEA account information (including their email address) current and accurate, and to notify BNEA if such email account ever changes or is terminated. BNEA assumes no responsibility for misdirected messages (i.e., messages sent to an unmonitored or deactivated email account). Misdirected messages could reveal user’s Personal Data about to unintended third parties.
Q12: Does BNEA Collect Information From Or About Children?
A12: The Online Services are not directed to children under thirteen (13) (or other age as required by local law). To comply with laws protecting children’s online privacy, BNEA does not knowingly collect Personal Data from children under thirteen (13) (or other age as required by local law). BNEA takes children’s privacy seriously and encourages parents to play an active role in their child’s online experience at all times. Children under age thirteen (13) (or other age as required by local law) should not use BNEA’s Online Services at any time. In the event BNEA learns that it has inadvertently collected Personal Data from a child under the age of thirteen (13) (or other age as required by local law), BNEA will take reasonable steps to promptly erase such information from BNEA’s records.
Q13: What Data Privacy Rights do Users Have and How do They Exercise Them?
A13:
Data Privacy Rights: Users of the Online Services have certain data protection rights under applicable law (including without limitation the California Privacy Laws and the General Data Protection Regulation (“GDPR”) and GDPR as it has been retained in the United Kingdom (“UK GDPR”)), such rights include:
- The Right to be Informed: The right to be informed about the collection and use of a user’s Personal Data, as outlined in this Privacy Policy.
- The Right to Access and Data Portability: The right to access the Personal Data BNEA processes about you as well as the right to data portability. This includes the right to request that BNEA disclose the following information in the twelve (12) months preceding the request:
- The categories of Personal Data BNEA collected about the user and the categories of sources from which we collected such Personal Data;
- The specific pieces of Personal Data BNEA collected about the user;
- The business or commercial purpose for collecting Personal Data about the user; and
- The categories of Personal Data about the User that BNEA otherwise shared or disclosed, and the categories of third parties with whom we shared or to whom BNEA disclosed such Personal Data (if applicable).
- Right to Data Correction: The right to have Personal Data corrected or erased.
- Right to be Forgotten: The right to delete Personal Data, including by deletion of an account and associated Personal Data.
- Right to Restrict Processing: The right to object or restrict the processing of a user’s Personal Data.
- Right to Withdraw Consent: The right to withdraw consent at any time for consent BNEA has obtained from a user, although this will not affect the lawfulness of the processing prior to the withdrawal.
- Right to Object: Users also have the right to object, at any time, to the processing of Personal Data based on BNEA’s legitimate interests.
- Right to not be Discriminated: The right to not be discriminated against for exercising these rights.
California Privacy Laws require BNEA to be transparent about any Personal Data it “sells” or “shares” with third-party partners, including without limitation, advertising partners. BNEA will not disclose any information for the purposes of cross-contextual behavioral or targeted advertising unless you have intentionally directed BNEA to do so, including by explicitly opting-in to such disclosures via a cookie banner or other similar prompt. Once a user opts-in to such disclosures, such user can opt-out by following the steps outlined in the section below.
BNEA has not “sold” or “shared” Personal Data for purposes of California Privacy Laws.
Exercising Data Privacy Rights: Users can exercise their data privacy rights by doing any of the following:
- Using Account Features: Users of Online Services that enable account creation can access, update, or request deletion of certain Personal Data they’ve disclosed to BNEA by logging into such user account (for example, these areas may be labeled as “My Account,” “Edit Profile,” “Settings,” or other similar names).
- Contact via Email: Users of Online Services that do not have account features can request access, update, or deletion of certain Personal Data by emailing BNEA at: privacy@bandainamcoent.com. BNEA will respond to all requests received within a reasonable timeframe and in accordance with applicable law.
- Submitting a Customer Support Ticket: Users of Online Services that do not have account features can request access, update, or delete Personal Data by submitting a ticket here;
- Calling a Toll-Free Number: Users may also contact BNEA at 1-888-956-2626.
- Opt-In or Opt-Out of Cookies and Tracking Technologies: Certain Online Services, like websites, may give you the option to opt-in or opt-out of cookies and tracking technologies. Users can exercise these rights by reading through the options presented via a cookie banner and selecting their cookie and tracking technology preferences. Users can also update their choices at any time (for example, such website may have a “Cookie Settings” or “Data Privacy” tab or button).
- Opt-Out of Marketing Emails: Users can opt-out of receiving marketing emails by clicking the “unsubscribe” button (or similarly worded button) located within the marketing email and confirming their selection.
Please note: The above methods of exercising data privacy rights are limited to data controlled or stored by BNEA, and not by its affiliates and related companies. For example, Bandai Namco ID is operated by BNEA’s affiliate, Bandai Namco Entertainment Inc. For questions relating to their privacy policy please visit https://bnfaq-support.channel.or.jp/inquiry/privacycontact_bandainamcoent and provide the required information. For inquiries or requests related to BNEA’s affiliates and related companies, please review such affiliate or related company’s relevant privacy policy.
BNEA may need additional information to verify a user’s identity, in which case, BNEA will contact the user to request for that information. Users may also designate an authorized agent to make these requests, in which case, BNEA will contact the authorized agent for additional information.
California Business and Professions Code Section 22581: Users of BNEA’s Online Services that reside in California may have the right to request and receive certain information about BNEA’s disclosure of such user’s Personal Data to third parties for their direct marketing purposes, and the right to exercise choices with respect to such disclosures. California Business and Professions Code Section 22581 permits registered users of BNEA’s Online Services that are under age eighteen (18) and reside in California, to request removal of content or information they have publicly posted through such Online Services. To make such a request, please send an email with a detailed description of the specific content or information to privacy@bandainamcoent.com. Please note: A request does not ensure complete or comprehensive removal of the content or information such users have posted and that there may be circumstances in which the law does not require or allow removal, even if properly requested.
Complaints for Users within the European Union or United Kingdom: In addition to the above, users of BNEA’s Online Services that reside in EU or UK also have the right to lodge complaints regarding this Privacy Policy, BNEA’s practices relating to processing of Personal Data hereunder, or their ability to exercise their Personal Data-related rights by lodging a complaint with a relevant supervisory authority. BNEA will respond to any such complaints promptly and within a reasonable time. In the event that BNEA fails to respond, or its response is insufficient or does not address the concern, BNEA has registered with JAMS to provide independent third-party dispute resolution at no cost to the complaining user. To contact JAMS and/or learn more about the company’s dispute resolution services, including instructions for submitting a complaint, please visit: https://www.jamsadr.com/eu-us-privacy-shield. In the absence of resolution by BNEA and JAMS, subject to certain conditions, complaining users may also seek to engage in binding arbitration through the Privacy Shield Panel by visiting: https://www.privacyshield.gov/article?id=How-to-Submit-a-Complaint.
Q14: Does BNEA Use Automated Decision Making?
A14: BNEA may use Personal Data collected from EEA Users under this Privacy Policy for the purposes described in Section A5, some of which involve automated decision making.
Q:15: How can Users Contact BNEA?
A:15 Users can contact BNEA via the methods outlined below:
Contact Information: The “data controller” and “data protection officer” for the information collected by BNEA under this Privacy Policy is:
Data Controller: Bandai Namco Entertainment America Inc.
23 Odyssey
Irvine, CA 92618
(949) 271-6000
privacy@bandainamcoent.com
Data Protection Officer: The Data Protection Officer can be contacted at privacy@bandainamcoent.com
Our data protection representative within the EEA is:
Bandai Namco Europe S.A.S
15 Rue Felix Mangini, CS90618
69009 Lyon Cedex 09, France
If users have questions or wish to send BNEA comments about this Privacy Policy, please e-mail or contact BNEA at:
Bandai Namco Entertainment America Inc.
Attn.: Legal
23 Odyssey
Irvine, CA 92618
(949) 271-6000
privacy@bandainamcoent.com
Any information a user provides to the above e-mail and postal mail addresses will not be used for direct marketing purposes, unless expressly requested by such user.