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.
With respect to the information referred to in item 2. below, the provision of personal data shall not be your obligation, and if you do not provide them, it will not have any influence on services and the use of games.
With respect to the information referred to in item 3. below, provision of part of personal data may be your obligation. If you do not provide them, it may have any influence on services and the use of games to be provided to you.

  1. 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.

  2. 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
    • other information obtained by SNK by separately expressing it, prior to collection

  3. 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.

  1. 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

  2. Personal information acquired by SNK when you use SNK’s mobile apps will be accumulated and analyzed, and used for the following purposes:

    • for provision, management and improvement of app services
    • for marketing activities for provision 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
    • statistical surveys and data analyses for the purpose of improving SNK’s services, such as development of new functions and better games in the future
    • other purposes separately expressed by SNK at collection

  3. Personal information acquired by SNK when you use online functions of SNK’s home and computer game software will be accumulated and analyzed, and used for the following purposes:

    • for provision, management and improvement of game services and their online functions
    • for marketing activities for provision 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
    • statistical surveys and data analyses for the purpose of improving SNK’s services, such as development of new functions and better games in the future
    • other purposes separately expressed by SNK at collection

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. Joint use

A variety of personal information you provided us may be jointly used by the following affiliates of SNK for the purposes of use as identified in Paragraph 3 of this Privacy Policy. All personal information made available to the related persons of SNK will be securely and appropriately managed in accordance with this Privacy Policy. The manager responsible for the joint use under the law of Japan shall be SNK. Please refer to the page of “COMPANY” for the address and other contact information of SNK.

  • Affiliates of SNK
  • SNK Entertainment Co., Ltd.

7. Disclosure of personal information to third parties

In principle, SNK does not provide third parties with a variety of personal information you provided us unless you give consent to such disclosure, except when SNK discloses such information only to the extent necessary for achieving the purposes of use as identified under Paragraph 3 of this Privacy Policy to SNK business partners and business contractors 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.

8. Security 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.

9. Customers under 16 years of age

Those under 16 years of age shall have their parent or guardian or agent therefor read this Privacy Policy to have them understand this Privacy Policy and the method of using personal information by SNK. When consent is necessary, if it turns out that a customer under 16 years of age has consented to the handling of personal information without the permission of the person who has parental authority, SNK may delete their personal information. If a parent or guardian or person who has parental authority finds that a customer under 16 years of age has consented to the handling of personal information, they may start the procedure for deletion by notifying SNK of it by email to the contact address referred to in the following section or the end of this Privacy Policy and requesting SNK to delete that customer’s personal information.

10. About rectification and deletion of personal information

Please make requests from this page for rectification and deletion of personal information, disclosure and other requests related to the handling of personal information, disclosure of record of third-party provision of personal information, or suspension of third-party provision, or for any other various inquiries. SNK will check contents and respond appropriately.

11. Inquiries for personal information

Our staff at the foregoing point of contact will check contents, confirm that such requests or inquiries are submitted by the information subject him/herself, and respond appropriately in order to handle a variety of inquiries related to the handling of personal information.

12. Use of Google Analytics

  1. 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.

  2. 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

13. Use of Adjust

  1. Applications

    • Some apps distributed by SNK use Adjust to understand the usage of services. The data collected by the use of Adjust is managed under Adjust Privacy Policy.
      Please refer to the below for Adjust Privacy Policy.

      Google Privacy Policy

      https://www.adjust.com/ja/terms/privacy-policy/

14. 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.

15. 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]

1.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.

  1. 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).

  2. 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).

  3. 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).

  4. 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).

  5. 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. You may withdraw your consent at any time. Withdrawal of your consent will not have any influence on legality of personal data processing by SNK based on your consent before the withdrawal.

  6. Other purposes separately expressed by SNK at collection

2.About your rights

Customers located in EEA have the rights shown below.

  1. Right to access to personal information

    • You have the right to check whether or not SNK uses your personal information, and if it does, the right to access your personal information. You may request a copy of your personal information and may ask SNK whether your personal information is used by SNK and the usage method and the purpose of the use, if used, and, when your personal information has been transferred to outside the area, the nature of the transfer.

  2. 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, provided that this does not apply when the change or rectification is impossible or takes a great deal of effort.

  3. Right to delete personal information

    • You have the right to demand the deletion of personal information possessed by SNK under certain conditions. You may ask SNK about those conditions, provided that this may not apply if the legal basis for handling lies anywhere else (e.g. a case where SNK needs to use that personal information to meet its responsibility pursuant to an agreement between you and SNK). SNK will convey your request to a third party that shares your personal information, provided that this does not apply if the deletion is impossible or takes a great deal of effort.

  4. Right to restrict the use of personal information

    • You have the right to restrict personal information processing by SNK under certain conditions. You may ask SNK about the details of the restriction. SNK will convey your request to a third party that shares your personal information, provided that this does not apply if the restriction is impossible or takes a great deal of effort. You may ask SNK about that third party.

  5. 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.

  6. Right to raise an objection

    • You have the right to raise an objection to handling your personal information by SNK for the legitimate interests of SNK or other person and to request discontinuation of the handling.

  7. Right to withdraw consent

    • You have the right to withdraw consent given by you. In this respect, withdrawal of your consent will not influence the legality of handling of your personal information based on your consent before the withdrawal.
      For exercise of the above right and the method of exercising it, please make an inquiry to SNK.

  8. Right to self-determination concerning profiling

    • You have the right to prevent profiling from having a serious influence on yourself.

  9. Right to file a complaint

    • You may also file a complaint with the data protection supervisory authorities in the country in which you reside, regarding SNK’s method of processing personal data.

3.About your rights

When you use services provided by SNK within EEA, SNK will process the data of personal information acquired under 2. (Types of personal information acquired and used by SNK) as mentioned above 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 or divulgence of personal information.

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

4.When a receiver of personal information is located in Japan

When a receiver of personal information is located in Japan, your personal information will be protected pursuant to Japan’s Act on the Protection of Personal Information. The European Commission and the UK have determined that personal data may be lawfully transferred to Japan without special permission being required, as Japan secures appropriate data protection (hereinafter “Adequacy Decision”).
When SNK transfers your data to the EEA or UK or a business entity outside Japan, SNK will protect your rights through your personal data pursuant to a data transfer agreement with the related receiver in accordance with the GDPR / UK GDPR.

5.A personal information storage period

A personal information storage period shall be as described in 4. (Storage period of personal information) as mentioned above. Besides, disclosure of personal information to third parties shall be as described in 7. (Disclosure of personal information to third parties) as mentioned above.

6.Contact addresses

SNK has appointed a data protection officer you can contact if you have a question or concern about your personal information. The contact address of SNK’s Data Protection Officer (DPO) is as follows.
Email: snk-dpo-office@iij-pj.jp

The contact addresses of agents in the EU and the UK are as follows.
Data Protection Representative Limited
Email: datarequest@datarep.com
DataRep, 3rd and 4th floor, Altmarkt 10 B/D, Dresden, 01067, Germany
DataRep, BPM 335368, 372 Old Street, EC1V 9AU, London, United Kingdom

The contact address of the administrator is as follows.
4-5-41, Miyahara, Yodogawa-ku, Osaka-shi, Osaka
SNK CORPORATION
Phone: 06-6734-5100