PRIVACY POLICY

SNK Corporation (“SNK”) protects your personal information by respecting the privacy of users using all contents managed and operated by SNK in accordance with the following basic policy. Please use this Privacy Policy as a reference when you use a variety of services provided by SNK online.

1. Compliance

SNK complies with the laws and regulations and other requirements related to personal information protection, and sets forth “Personal Information Protection Regulations,” conducts management and education and endeavors for continuous improvement and maintenance in order to disseminate such Regulation thoroughly to SNK Employees(*) and relevant parties.
(*) SNK Employees mean all persons engaged in SNK, including officers, employees (regular employees, contract employees and part-time employees) and temporary employees.

2. Types of personal information acquired and used by SNK

Personal information acquired from you and used by SNK includes the following information.
(i) Personal information acquired by SNK when you communicate and make inquiries about SNK’s products, services and other matters.
・name, telephone number and mail address
・any and all other information provided by you to SNK that is necessary for SNK to reply to communications and inquiries.
(ii) Personal information acquired by SNK when you use SNK’s mobile apps
・in-app registered information and activities (including the account name, game play contents and history, purchase history of in-app currencies, friendship status, play status and results, chat contents, etc.)
・information of your device using apps (including the product model, OS, communication carrier, locale setting, advertising identifier (IDFA, etc.), and other information such as identifiers proper to your information device)
・IP address
・cookie.
(iii) Personal information acquired by SNK when you use online functions of SNK’s home and computer game software
・in addition of the information such as the above (ii), individual ID granted by a platform provider, user name, game play contents and activities
SNK clarifies the purpose of use when collecting such personal information and uses such personal information only within the scope of the purpose. We may ask the preferences or interests of each user when we collect personal information, which we will use for the development of products in high demand or enhancement of our services such as distribution of appropriate contents.

3. Purposes of use of personal information

SNK uses the personal information acquired as above for the following purposes.
(i) Personal information acquired by SNK when you make inquiries about SNK’s products, services and other matters.
・to ensure to respond to inquiries securely and appropriately
(ii) Personal information acquired by SNK when you use SNK’s mobile apps
・for provision, management and improvement of app services
・for prevention of fraud within apps
・for management of billing
・for advertising distribution and measurement of the effectiveness of advertising distribution
・to ensure to respond to inquiries securely and appropriately
(iii) Personal information acquired by SNK when you use online functions of SNK’s home and computer game software
・for provision, management and improvement of game services and their online functions
・for prevention of fraud within game software
・to ensure to respond to inquiries securely and appropriately

4. Storage period of personal information

SNK stores and retains collected personal information until such personal information becomes no longer required for the fulfilment of the purpose of use (including cases in which your account is deleted). Personal information that is no longer required for the fulfilment of the purpose of use will be promptly deleted or anonymized.

5. Transmission of personal information

While SNK pays the maximum attention to the protection of personal information, SNK cannot guarantee the security of personal information during transmission. When transmitting information, you do so at your own risk due to the nature of the Internet.

6. Disclosure of personal information to third parties

In principle, SNK does not provide third parties with a variety of information you provided us unless you give consent to such disclosure, except when SNK discloses such information only to the extent necessary to SNK business partners and business contractors and affiliate companies with whom SNK has concluded a confidential agreement in advance (SNK may use third party information collection and advertising distribution modules for research on use of services, prevention of fraudulent acts, advertising distribution, etc.), when SNK is requested to disclose such information under laws and regulations, or when SNK is requested to disclose such information by judicial or administrative agencies.

7. Management of personal information

SNK endeavors to securely and appropriately manage personal information by establishing a person responsible for management and taking appropriate security measures in order to prevent unauthorized access to, or loss, destruction, falsification and divulgence of personal information.

8. About rectification and deletion of personal information

Please make requests for disclosure and inquiries related to the handling of personal information from this page. SNK will check contents and respond appropriately.

9. Inquiries for personal information

Our staff will check contents and respond appropriately in order to handle a variety of inquiries related to the handling of personal information.

10. Use of Google Analytics

・Websites
SNK uses the services provided by Google Analytics in the websites operated by SNK in order to understand the usage. Google Analytics use cookies and collects data without personally identifying information. The data collected by the use of Google Analytics is managed under Google Privacy Policy.
・Applications
Some apps distributed by SNK use Google Analytics to understand the usage of services. The data collected by the use of Google Analytics is managed under Google Privacy Policy.
Please refer to the below for Google Privacy Policy.

Google Privacy Policy
https://policies.google.com/privacy?hl=en

11. Information collection module

SNK endeavors to securely and appropriately manage personal information by establishing a person responsible for management and taking appropriate security measures in order to prevent unauthorized access to, or loss, destruction, falsification and divulgence of personal information.
The advertising distributors may automatically acquire the information of users for the purpose of advertising distribution in apps distributed by SNK. Please check the links of the following advertising distributors’ applications privacy policies for information to be acquired, purposes of use, provision to third parties, etc.

AdMob (Google Inc.)
https://policies.google.com/technologies/ads?hl=en

12. External links

There may be links to others’ websites on SNK’s website. However, SNK is not involved in the operation or management of websites of such links. Therefore, SNK bears no responsibility for the handling of personal information on websites of such links.

[For customers within EEA]
・Purposes and legal basis for personal information processing
The legal basis related to processing of personal information acquired for each purpose of use is as follows.
(i) To ensure to respond to inquiries securely and appropriately
SNK uses personal information provided in order to securely and appropriately respond to your inquiries or requests related to SNK’s overall products and services (including SNK’s apps and game software).
The GDPR legal basis for personal information processing for this purpose is Article 6, Paragraph 1(b).
(ii) For provision, management and improvement of app services
SNK uses personal information for performance of a contract, which is provision of app services to customers. SNK may process personal information for legitimate pursuit of profits, which is improvement of app services for customers. SNK analyses usage of app services by using Google Analytics, app for legitimate pursuit of profits, which is improvement of apps.
The GDPR legal basis for personal information processing for this purpose is Article 6, Paragraph 1(b) or (f).
(iii) For prevention of fraud within apps
SNK processes personal information for SNK’s legitimate pursuit of profits, which is optimization of SNK’s business performance and enhancement of reliability of services through prevention of fraud within apps.
The GDPR legal basis for personal information processing for this purpose is Article 6, Paragraph 1(f).
(iv) For management of billing
If you purchase items within a game within app services provided by SNK, SNK processes personal information to the extent necessary for the performance of such contract. Furthermore, it enables SNK to pursue its legitimate profits including pursuit of revenues through analysis of billing status.
The GDPR legal basis for personal information processing for this purpose is Article 6, Paragraph 1(b) or (f).
(v) For advertising distribution and measurement of the effectiveness of advertising distribution
SNK processes personal information to transmit advertising related to products or services of SNK’s or of third parties. SNK acquires your individual consent to acquisition of information for the purpose of advertising distribution. After acquiring individual consent, SNK processes personal information for legitimate pursuit of profits, which is optimization of SNK’s marketing and advertising distribution.
The GDPR legal basis for personal information use for this purpose is individual consent for advertising distribution, and Article 6, Paragraph 1(f) for measurement of the effectiveness of advertising distribution.

・About your rights
Customers located in EEA have the rights shown below.
(i) Right to access to personal information
You have the right to check whether or not SNK uses your personal information, and if yes, the right to access to your personal information.
(ii) Right to rectify personal information
You have the right to request SNK to change or rectify such personal information if personal information acquired and used by SNK is inaccurate.
(iii) Right to delete personal information
You have the right to demand the deletion of personal information possessed by SNK under certain conditions.
(iv) Right to restrict the use of personal information
You have the right to restrict personal information processing by SNK under certain conditions.
(v) Right to data portability
You have the right to receive personal information retained by SNK and transfer such personal information to other controllers (including the right to request SNK to provide directly such information to other controllers).
In addition to the above rights, you have the right to at any time withdraw your consent to SNK in respect of personal information processing and transfer. Please contact the below about exercising and the way to exercise the above rights.
Furthermore, you have the right to object to SNK and the right to object to the regulatory authorities in respect of the use and processing of personal information.
Please contact the personal information protection regulatory authority of your country of residence (location) when objecting to regulatory authorities.

・About your rights
When you use services provided by SNK within EEA, SNK will process the data of personal information acquired under the above 2 after transferring such data from EEA to Japan. SNK endeavors to securely and appropriately manage personal information by establishing a person responsible for management and taking appropriate security measures in order to prevent unauthorized access to, or loss, destruction, falsification and divulgence of personal information. The legal basis for transfer of personal information from EEA to Japan is Article 49, Paragraph 1(b) of GDPR as the transfer of personal information to Japan is necessary for the performance of provision of app services.

If you refuse the acquisition of personal information by SNK, SNK may not be able to provide services.