Privacy Policy Promise with customers

Bandai Namco Network Services Inc. (hereinafter referred to as the “Company,” “we,” or “us”) wants you to be familiar with how we collect, use and disclose information. This Privacy Policy describes our practices in connection with information that we collect through:

  • ・Websites operated by us from which you are accessing this Privacy Policy (hereinafter the "Websites");
  • ・Our social media pages on which we post a link to this Privacy Policy (hereinafter collectively referred to as "social media pages");
  • ・HTML-formatted email messages that we send to you that link to this Privacy Policy or other communications with you; and
  • ・Offline business interactions you have with us.

Collectively, we refer to the Websites, Social Media Pages, emails, and offline business interactions as the “Services.”

1. Types of Personal Information Acquired

“Personal Information” is information that identifies you as an individual or relates to an identifiable individual. The Services collect Personal Information, including:

  • ・Contact information (addresses, names, telephone numbers, email addresses, fax numbers, etc.)
  • ・The Services' account information (user IDs, passwords, etc.)
  • ・Information concerning personnel hiring (gender, date of birth, work history, academic history, qualifications, etc.)
  • ・Employee information (organizational information, insurance numbers, health-related information, images, etc.)
  • ・Information about business transactions (business partners' organizational information, bank account numbers, etc.)

2. Means of collecting Personal Information

We and our service providers collect Personal Information in a variety of ways, including:

Through the Services.

We collect Personal Information through the Services, for example, when you sign up for a newsletter, register an account to access the Services, participate in the Company's personnel recruitment or other projects involving application submission, contact customer service, place an order, or make a purchase by phone or email.

From Other Sources.

We receive your Personal Information from other sources, for example, from publicly available databases and our joint marketing partners, when they share the information with us.
If you connect your social media account to your Services account, you will share certain Personal Information from your social media account with us, for example, your name, email address, photo, list of social media contacts, and any other information that may be or you make accessible to us when you connect your social media account to your Services account. We refer to this as “social sharing.”

We need to collect Personal Information in order to provide the requested Services to you. If you do not provide the information requested, we may not be able to provide the Services. If you disclose any Personal Information relating to other people to us or to our service providers in connection with the Services, you represent that you have the authority to do so and to permit us to use the information in accordance with this Privacy Policy.

3. Purposes of Processing Personal Information

We and the providers of the Services process personal information for the following purposes:

Providing the functionality of the Services and fulfilling your requests.

  • ・To provide the Services’ functionality to you, such as arranging access to your registered account, and providing you with related customer service.
  • ・To respond to your inquiries and fulfill your requests, when you contact us via one of our email addresses, online contact forms or otherwise, for example, when you send us questions, suggestions, or complaints, or when you request a quote for or other information about our Services.
  • ・To complete your transactions, verify your information, and provide you with related service.
  • ・To send administrative information to you, such as changes to our terms, conditions, and policies.
  • ・To allow you to send messages to another person through the Services if you choose to do so.

We will engage in these activities to manage our contractual relationship with you and to comply with a legal obligation.

Providing you with our newsletter and/or other marketing materials.

  • ・To send you marketing related emails, with information about our services, new products and other news about our company.
  • ・We will engage in this activity with your consent or where we have a legitimate interest.

Analyzing Personal Information for business reporting and providing personalized services.

  • ・To analyze or predict our users’ preferences in order to prepare aggregated trend reports on how our digital content is used, so we can improve our Services.
  • ・To better understand your interests and preferences, so that we can personalize our interactions with you and provide you with information and/or offers tailored to your interests.
  • ・To better understand your preferences so that we can deliver content via our Services that we believe will be relevant and interesting to you.

We will provide personalized services based on our legitimate interests, and with your consent to the extent required by applicable law.

Allowing you to participate in contests or other projects involving application submission, including personnel recruitment.

  • ・We may offer you the opportunity to participate in a contest planned by us or other projects involving application submission, including personnel recruitment.
  • ・Some of these projects have additional rules containing information about how we will use and disclose your Personal Information. Please confirm those additional rules before choosing to participate.

We use this information to manage our contractual relationship with you.

Aggregating and anonymizing Personal Information.

We may aggregate and/or anonymize (process personal information so that it is not possible to identify an individual) Personal Information so that it will no longer be considered Personal Information. We do so to generate other data for our use, which we may use and disclose for any purpose, as it no longer identifies you or any other individual.

Accomplishing our business purposes. (or more specifically, the objectives listed below)

  • ・For data analysis, for example, to improve the efficiency of our Services;
  • ・For audits, to verify that our internal processes function as intended and to address legal, regulatory, or contractual requirements;
  • ・For fraud and security monitoring purposes, for example, to detect and prevent cyberattacks or attempts to commit identity theft;
  • ・For developing new services;
  • ・For enhancing, improving, repairing, maintaining, or modifying our current services, as well as undertaking quality and safety assurance measures;
  • ・For identifying usage trends, for example, understanding which parts of our Services are of most interest to users;
  • ・For determining the effectiveness of our Services, so that we can adapt our Services to the needs and interests of our users; and
  • ・For operating and expanding our business activities, for example, understanding which parts of our Services are of most interest to our users so we can focus our energies on meeting our users’ interests.

We engage in these activities to manage our contractual relationship with you, to comply with a legal obligation, and/or based on our legitimate interest.

4. Recipients of Disclosed Personal Information

We disclose Personal Information:

4-1. Recipients of Disclosed Personal Information

To our affiliates for the purposes described in this Privacy Policy.
You can consult the list and location of our group companies here:
https://www.bandainamco.co.jp/en/about/grouplink.html

To our third party service providers, to facilitate services they provide to us.
These can include providers of services such as website hosting, data analysis, payment processing, order fulfillment, information technology and related infrastructure provision, customer service, email delivery, auditing, and other services.

To third party sponsors of contests, and other similar projects involving application submission.

By using the Services, you may elect to disclose Personal Information.
On message boards, chat, profile pages, blogs, and other services to which you are able to post information and content (including, without limitation, our Social Media Pages). Please note that any information you post or disclose through these services will become public and may be available to other users and the general public.

4-2. Purposes of Use and Disclosure to Other than Those Listed Above

We also use and disclose your Personal Information as necessary or appropriate, in particular when we have a legal obligation or legitimate interest to do so:

To comply with applicable law and regulations.
This may include laws outside your country of residence.

To cooperate with public and government authorities.
To respond to a request or to provide information we believe is necessary or appropriate. These can include authorities outside your country of residence.

To cooperate with law enforcement.
For example, when we respond to law enforcement requests and orders or provide information we believe is important.

For other legal reasons.
To enforce our terms and conditions; and to protect our rights, privacy, safety or property, and/or that of our affiliates, you or others.

In connection with a sale or business transaction.
We have a legitimate interest in disclosing or transferring your Personal Information to a third party in the event of any reorganization, merger, sale, joint venture, assignment, transfer, or other disposition of all or any portion of our business, assets, or stock (including in connection with any bankruptcy or similar proceedings).

5. Other Information (including an explanation regarding cookies)

“Other Information” is any information that does not reveal your specific identity or cannot identify an individual. The Services collect Other Information such as:

  • ・Browser and device information
  • ・App usage data
  • ・Demographic information and other information that does not reveal your specific identity
  • ・Information that has been aggregated in a manner such that it no longer reveals your specific identity

5-1. Collection of Other Information

We and our service providers may collect Other Information in a variety of ways, including:

Your browser or device.
Certain information is collected by most browsers or automatically through your device, such as your Internet browser type and version. We use this information to ensure that the Services function properly.

Cookies
Cookies are pieces of information stored directly on the computer that you are using.
Websites run by this company do not use cookies, and no customer information will be collected.

5-2. Use and Disclosure of Other Information

We may use and disclose Other Information for any purpose, except where we are required to do otherwise under applicable law. If we are required to treat Other Information as Personal Information under applicable law, we may use and disclose it for the purposes for which we use and disclose Personal Information as detailed in this Policy. In some instances, we may combine Other Information with Personal Information. If we do, we will treat the combined information as Personal Information as long as it is combined.

6. Security

We seek to use reasonable organizational, technical, and administrative measures to protect Personal Information within our organization. Unfortunately, no data transmission or storage system can be guaranteed to be 100% secure. If you have reason to believe that your interaction with us is no longer secure, please immediately notify us in accordance with the “Contacting Us” section below.

7. User Options Pertaining to the Use and Disclosure of Personal Information

We provide you with options pertaining to the use and disclosure of users' personal information for marketing purposes. To prevent us from carrying out the following processing, you may make a request to us (hereinafter referred to as "opt out"):

(1) Receipt of marketing-related emails from us.
If you no longer want to receive marketing-related emails from us on a going-forward basis, you may opt out by contacting us as shown under "16. Contact for Inquiries Concerning Personal Information."

We will try to comply with your requests as soon as reasonably practicable. Please note that if you opt out of receiving marketing-related emails from us, we may still send you important administrative messages, from which you cannot opt out.

8. Methods for Accessing, Changing and Deleting Your Personal Information

If you request us to disclose, correct, discontinue using, or delete your Personal Information, or notify you of the purpose of use of your Personal Information, please fill out the applicable form among the forms attached below under the title “Request Forms for Disclosure of Personal Information” and send it with a copy of either of your (i) driver’s license (ii) passport (iii) health insurance card (in case your domicile of origin or medical records are indicated, please do not copy them) enclosed to our address below by post. Further, if you make the above request through your legal representative or proxy, please enclose the necessary documents listed in the following applicable form.

Fees:

The following fee will be charged for your request to disclose your Personal Information and to provide notice of the intended uses of your Personal Information.
No fees will be charged for your request(s) to correct, discontinue the use of, or delete your Personal Information. Fee: 800 yen per request.
Payment Method: Please enclose postal money order (issued by post office) with the above request.

Attention: Contact for Personal Information Matter, Bandai Namco Network Services Inc.
Address: 5-37-8 Shiba, Minato-ku, Tokyo, 108-0014, Japan

Please note that in case the above form submitted by you was incomplete or incorrect, we may not be able to respond to you appropriately.
We will use your Personal Information provided by you through the above request procedure for the purpose of responding to your request of disclosure, correction, etc. of your Personal Information appropriately, and we will keep it strictly confidential for a certain period. Further, please note that we will not return the above form and the enclosures provided by you if we are unable to successfully verify your identity.

9. Retention Period

We retain Personal Information for as long as needed or permitted in light of the purposes for which it was obtained and consistent with applicable law.

The criteria used to determine our retention periods include:

  • ・The length of time we have an ongoing relationship with you and provide the Services to you (for example, for as long as you have an account with us or keep using the Services);
  • ・Whether there is a legal obligation to which we are subject (for example, certain laws require us to keep records of your transactions for a certain period of time before we can delete them); or
  • ・Whether retention is advisable in light of our legal position (such as in regard to applicable statutes of limitations, litigation, or regulatory investigations).

10. Services Provided by Third Parties

This Privacy Policy does not address, and we are not responsible for, the privacy, information, or other practices of any third parties, including any third party operating any website or service to which the Services link. The inclusion of a link on the Services does not imply endorsement of the linked site or service by us or by our affiliates.

In addition, we are not responsible for the information collection, use, disclosure, or security policies or practices of other organizations, such as Facebook, Apple, Google, Microsoft, RIM, or any other app developer, app provider, social media platform provider, operating system provider, wireless service provider, or device manufacturer, including with respect to any Personal Information you disclose to other organizations through or in connection with the Apps or our Social Media Pages.

11. Use of Services by Minors

In case the Company intends to obtain Personal Information from minors, it will do so after obtaining the consent of their legal representatives as necessary.

12. Jurisdiction and Cross-border Transactions

Your Personal Information may be stored and processed in any country where we have facilities or in which we engage service providers, and by using the Services you understand that your information will be transferred to countries outside of your country of residence, including the United States, which may have data protection rules that are different from those of your country. In certain circumstances, courts, law enforcement agencies, regulatory agencies or security authorities in those other countries may be entitled to access your Personal Information.

13. Supplementary Information Regarding the EEA

Some non-EEA countries are recognized by the European Commission as providing an adequate level of data protection according to EEA standards (the full list of these countries is available at Adequacy decisions [europa.eu]). For transfers from the EEA to countries not considered adequate by the European Commission, we have put in place adequate measures, such as standard contractual clauses adopted by the European Commission, to protect your Personal Information. You may obtain a copy of these measures by contacting us in accordance with the “Contact Us” section below.

14. Sensitive Information

Unless we request it, we ask that you not send us, and you not disclose, any sensitive Personal Information (e.g., social security numbers, information related to racial or ethnic origin, political opinions, religion or other beliefs, health, biometrics or genetic characteristics, criminal background, or trade union membership) on or through the Services or otherwise to us.

15. Updating of the Privacy Policy

The “Last Updated” at the bottom of this Privacy Policy indicates when this Privacy Policy was last revised. Any changes will become effective when we post the revised Privacy Policy on the Services.

16. Contact for Inquiries Concerning Personal Information

Bandai Namco Network Services Inc. (Representative: Takayuki Ikeda, President and Representative Director; address: Bandai Namco Mirai-Kenkyusho, 5-37-8 Shiba, Minato-ku, Tokyo) is the company responsible for collection, use, and disclosure of your Personal Information under this Privacy Policy.
If you have any questions about this Privacy Policy or complaints about our handling of your Personal Information, please contact the department below for further details.

●Contact for Inquiries Concerning Personal Information:
Corporate Department
Bandai Namco Network Services Inc.
Bandai Namco Mirai-Kenkyusho
5-37-8 Shiba, Minato-ku, Tokyo, 108-0014, Japan

17. Supplementary Information Regarding the EEA

You may also:

  • ・If applicable, please contact us according to "16. Contact for Inquiries Concerning Personal Information."
  • ・Lodge a complaint with an EU/EEA data protection authority for your country or region where you have your habitual residence or place of work or where an alleged infringement of applicable data protection law occurs. A list of data protection authorities is available at http://ec.europa.eu/newsroom/article29/item-detail.cfm?item_id=612080.

18. Supplementary Information Regarding California

Pursuant to the California Privacy Rights Act of 2018 (hereinafter referred to as "CPRA"), we are providing the following details regarding the categories of Personal Information that we collect, use, and disclose about California residents. This section does not apply to our job applicants, employees, contractors, owners, directors, or officers where the Personal Information we collect about those individuals relates to their current, former, or potential role with us.

18-1. Sources of Personal Information

We collect Personal Information from:
・Our group companies, publicly available online sources and joint business partners.

18-2. Categories of Personal Information Collected, Disclosed, Sold, and Shared

Following are details of the categories of Personal Information that we shared about California residents, the categories of Personal Information that we "sell" or "share" for the purpose of cross-context behavioral advertising, and the categories of Personal Information that we have disclosed for business purposes in the preceding 12 months.

Types of Personal Information Types of Personal Information Parties to Whom Personal Information is Sold Parties with Whom We Share Cross-Context Behavioral Ads
A. Identifiers Group companies/trusted service providers/joint business partners/providers of promotions such as sweepstakes and contests, etc. Not sold Not shared
Name, contact details, IP address, and other online identifiers, etc.
B. Customer Record Information that is Personal Information, as defined in the California Customer Records Act Group companies/trusted service providers/joint business partners/providers of promotions such as sweepstakes and contests, etc. Not sold Not shared
Name, contact details, medical information, insurance information, education information, employment information, etc.
C. Protected Class Information Group companies/trusted service providers/joint business partners/providers of promotions such as sweepstakes and contests, etc. Not sold Not shared
Age, gender, etc.
D. Online Use Information Group companies/trusted service providers/joint business partners/providers of promotions such as sweepstakes and contests, etc. Not sold Not shared
Browsing history and interactions with the Services
E. Employment Information Group companies/trusted service providers/joint business partners/providers of promotions such as sweepstakes and contests, etc. Not sold Not shared
Information on occupation or employment, such as work history and prior employer
F. Education Information Group companies/trusted service providers/joint business partners/providers of promotions such as sweepstakes and contests, etc. Not sold Not shared
Education information subject to the federal Family Educational Rights and Privacy Act, such as student records
K. Inferred Information Group companies/trusted service providers/joint business partners/providers of promotions such as sweepstakes and contests, etc. Not sold Not shared
Making a profile of an individual’s preferences, behaviors, or characteristics, for example, with an inference derived from any of the above Personal Information
L. Sensitive Personal Information Group companies/trusted service providers/joint business partners/providers of promotions such as sweepstakes and contests, etc. Not sold Not shared
・Social security number, driver's license, state-issued ID or passport number, account login number, financial account, password, credentials, exact geographic location, and content of the email, or text message that we are not the intended recipient of the communication
・Personal Information collected and analyzed regarding an individual's health
・Personal Information collected and analyzed regarding an individual's sexual life or sexual orientation

We have not "sold" or "shared" Personal Information for purposes of the CPRA in the past 12 months. We do not "sell" or "share" Personal Information of minors under 16 years of age.

18-3. Purposes of Use for Personal Information

We use these categories of Personal Information for the purposes of operating, managing, and maintaining our business, providing our products and services, and accomplishing our business purposes and objectives, including using Personal Information to:

  • ・Respond to inquiries from you;
  • ・Plan, improve and maintain our services;
  • ・Conduct research, analytics, and data analysis;
  • ・Establish and maintain user accounts and authenticate user identity;
  • ・Conduct contests, projects involving application submission, research and surveys;
  • ・Maintain our property and our records, and undertake quality and safety assurance measures;
  • ・Conduct risk and security control and monitoring, and detect and prevent fraud;
  • ・Perform identity verification, accounting, audit, and other internal functions, such as internal investigations and record-keeping;
  • ・Carry out corporate transactions, such as mergers, joint ventures, or acquisitions; and
  • ・Comply with law, legal process, and internal policies, and exercise and defend legal claims.

We may also use sensitive Personal Information as permitted by applicable laws for the performance of services for our business, provision of goods or services requested by customers, ensuring security and integrity, short-term temporary use such as the display of first-party non-personalized advertising, order processing and fulfillment, account maintenance, customer service provision, confirmation of customer information, payment processing, provision of financing, activities related to quality and safety management or product improvement.

18-4. Individual Rights and Demands

If you are a California resident, you may make the following requests:

(1) “Requests to Know”
You may request that we disclose to you the following information covering the 12 months preceding your request:
i. The categories of Personal Information we collected about you and the categories of sources from which we collected such Personal Information;
ii. The specific contents of Personal Information we collected about you;
iii. Business purpose when collecting Personal Information about you; and
iv. The categories of Personal Information about you that we otherwise shared or disclosed, and the categories of third parties with whom we shared or to whom we disclosed such Personal Information (if applicable).

(2) “Requests to Delete”
You may request that we delete Personal Information we collected from you.

(3) “Requests to Correct”
You may request that we correct any inaccurate Personal Information we collected from you.

To make a Request to Know or a Request to Delete, please contact us according to "16. Contact for Inquiries Concerning Personal Information." We will verify and respond to your request consistent with applicable law, taking into account the type and sensitivity of the Personal Information subject to the request. We may need to request additional Personal Information from you, such as name, email address, mailing address and information regarding your previous interactions with us, in order to verify your identity and protect against fraudulent requests. If you maintain a password-protected account with us, we may verify your identity through our existing authentication practices for your account and require you to re-authenticate yourself before disclosing or deleting your Personal Information. You may make a request on behalf of a child who is under 13 years old if you are the child’s parent or legal guardian. If you make a Request to Delete, we may ask you to confirm your request before we delete your Personal Information. You have the right to be free from unlawful discrimination for exercising your rights under the CPRA.

18-5. Authorized Agent

If you are applying as an authorized agent on behalf of a California resident, you may use the submission method described above. As part of our verification process, we may require you to submit certification regarding your status as an authorized agent, if applicable, which may include the following:

  • ・Proof of registration with the California Secretary of State to do business in California; and/or
  • ・Power of Attorney from a California resident pursuant to Probate Code Sections 4121 through 4130; and/or

If you are making an inquiry request or deletion request on behalf of a California resident and have not provided us with a Power of Attorney from the resident pursuant to Probate Code Sections 4121 through 4130, we may also require the resident to:

  • ・directly verify their identity with us; and
  • ・directly confirm whether the resident has permitted to submit a "Request to Know" or “Request to Delete."

18-6. Anonymized Information

If we retain or use anonymized information, we will continue to retain and use the same only in an anonymized manner and will not re-identify the information.

End

Initially posted on October 1, 2018
Last updated: October 1, 2023