8. CHILDREN'S INFORMATION
Protecting the privacy of young children is especially important to SEGA. For that reason, SEGA does not knowingly collect, maintain, sell or share personal information or non-personally identifiable information from underage users other than as permitted by law in support of our internal operations. SEGA may identify underage users to third-party advertisers to ensure that third-party advertisers (1) do not collect personal information or non-personally identifiable information about those underage users and (2) do not show age-inappropriate ads to those underage users.
In this Privacy Policy, any reference to underage users refers to those under the age of consent to the processing of personal information in their country of residence:
* Croatia, Germany, Hungary, Ireland, Luxembourg, Malta, Netherlands, Poland, Romania, Slovakia – 16 or under
* Czech Republic, France, Greece, Slovenia – 15 or under
* Austria, Bulgaria, Cyprus, Italy, Lithuania, Spain – 14 or under
* United States, United Kingdom and any EU countries not listed above – 13 or under
If SEGA learns that personal information of underage users has been collected, other than for support of our internal operations, SEGA will take reasonable steps to remove such information. If you believe that we may have unintentionally collected personal information about your child who is underage, you may contact us using the details provided below.
9. CALIFORNIA PRIVACY NOTICE
This section supplements our Privacy Policy with additional information for California residents about our information collection and use practices as required by the California Consumer Privacy Act 2018, as amended by the California Privacy Rights Act of 2020 (the “CCPA”), Privacy Rights for California Minors in a Digital World, and the California Shine the Light and provides information about California residents’ rights under those laws. In this section, the terms “personal information” and “sensitive personal information” have the meaning set forth in the CCPA.
The following chart provides information about our practices in the 12 months leading up to the effective date of this Privacy Policy in relation to the categories of personal information that we have collected from California residents generally, the purposes for which we use the information, and the categories of third parties to whom we disclose the information for business and operational purposes.
Categories of personal information collected (see “The Information We Collect” section above for additional information) Purpose of use Categories of third parties to whom we disclose the personal information for business and operational purposes (See “How We Disclose the Information We Collect” section above for additional information)
Identifiers
such as name, address, phone number, username, and email address; and information about your browser or device such as your IP address and device IDs • Process orders
• Provide the Products and customer service
• Verify and authenticate your information, account, and interactions with us
• Communicate with you
• Personalize your experience and customize the Products
• Understand your interests and engage in research, analysis, and reports
• Our marketing and advertising purposes
• Bug detection and error reporting
• Security, fraud, and legal compliance • Service providers
• Advertising partners and advertisers
• Affiliates
• Entities for legal and security purposes
• Entities for sales or transfer of business or assets
• Unaffiliated third parties for their advertising purposes
• Others with your consent
Demographic information
such as age or date of birth and gender • Provide the Products and customer service
• Verify and authenticate your information, account, and interactions with us
• Personalize your experience and customize the Products
• Understand your interests and engage in research, analysis, and reports
• Our marketing and advertising purposes
• Bug detection and error reporting
• Security, fraud, and legal compliance • Service providers
• Advertising partners and advertisers
• Affiliates
• Entities for legal and security purposes
• Entities for sales or transfer of business or assets
• Unaffiliated third parties for their advertising purposes
• Others with your consent
We do not use your age or gender to deliver targeted advertising to you based on your age or gender in our mobile apps, nor do we share your age or gender with third parties to enable them to deliver targeted advertising to you based on your age or gender in our mobile apps, except that we may inform third parties if we know that you are under the age of consent (see Section 8: Children's Information).
Customer service information
such as questions and other messages you address to us directly through online forms, by email, over the phone, or by post • Process orders
• Provide the Products and customer service
• Communicate with you
• Improve the Products
• Bug detection and error reporting
• Security, fraud, and legal compliance • Service providers
• Affiliates
• Entities for legal and security purposes
• Entities for sales or transfer of business or assets
• Others with your consent
Financial information
such as credit card information stored by our payment processors on our behalf • Process orders
• Communicate with you
• Verify and authenticate your information, account, and interactions with us
• Provide the Products and customer service
• Bug detection and error reporting
• Security, fraud, and legal compliance • Third party payment processors
• Entities for legal and security purposes
Transactional information
such as information about your transactions with us and related to your attendance at events or programs • Process orders
• Communicate with you
• Provide the Products and customer service
• Improve the Products
• Understand your interests and engage in research, analysis, and reports
• Our marketing and advertising purposes
• Bug detection and error reporting
• Security, fraud, and legal compliance • Service providers
• Advertising partners and advertisers
• Affiliates
• Entities for legal and security purposes
• Entities for sales or transfer of business or assets
• Unaffiliated third parties for their advertising purposes
• Others with your consent
User-generated content
such as any user-generated content you voluntarily decide to provide through the Products, including photographs, or other information you provide in connection with your account • Communicate with you
• Provide the Products and customer service
• Improve the Products
• Understand your interests and engage in research, analysis, and reports
• Our marketing and advertising purposes
• Bug detection and error reporting
• Security, fraud, and legal compliance • Service providers
• Advertising partners and advertisers
• Affiliates
• Entities for legal and security purposes
• Entities for sales or transfer of business or assets
• Others with your consent
Survey, research, feedback, or sweepstakes information
such as information you provide in response to a survey or sweepstakes on in relation to the Products • Communicate with you
• Provide the Products and customer service
• Improve the Products
• Understand your interests and engage in research, analysis, and reports
• Bug detection and error reporting
• Security, fraud, and legal compliance • Service providers
• Affiliates
• Entities for legal and security purposes
• Entities for sales or transfer of business or assets
• Unaffiliated third parties for their advertising purposes
• Others with your consent
Internet network and device activity data
such as browsing information and usage information • Provide the Products and customer service
• Personalize your experience and customize the Products
• Improve the Products
• Understand your interests and engage in research, analysis, and reports
• Our marketing and advertising purposes
• Bug detection and error reporting
• Security, fraud, and legal compliance • Service providers
• Advertising partners and advertisers
• Affiliates
• Entities for legal and security purposes
• Entities for sales or transfer of business or assets
• Others with your consent
Geolocation information
such as your approximate location based on IP address • Process orders
• Provide the Products and customer service
• Personalize your experience and customize the Products
• Improve the Products
• Understand your interests and engage in research, analysis, and reports
• Our marketing and advertising purposes
• Bug detection and error reporting
• Security, fraud, and legal compliance • Service providers
• Advertising partners and advertisers
• Affiliates
• Entities for legal and security purposes
• Entities for sales or transfer of business or assets
• Others with your consent
Information about others
such as if you submit information about others • Communicate with you and others
• Provide the Products and customer service
• Improve the Products
• Understand your interests and engage in research, analysis, and reports
• Our marketing and advertising purposes
• Bug detection and error reporting
• Security, fraud, and legal compliance • Service providers
• Affiliates
• Entities for legal and security purposes
• Entities for sales or transfer of business or assets
• Others with your consent
Other information
any other information that you provide in the course of using the Products • Purposes of use will depend on the additional information you provide • Disclosure will depend on the additional information you provide
SALE AND SHARING OF PERSONAL INFORMATION
As explained in the “How We Disclose Information” section above, we sometimes disclose information to unaffiliated third parties we collaborate with or that provide offers that we think may be of value to you. This disclosure of information may be considered a “sale” or “sharing” under the CCPA. We also provide personal information to third-party advertising providers for targeted advertising purposes, so that we can provide you with more relevant and tailored ads regarding our services, or use analytics partners to assist us in analyzing the use of our services and our user/customer base. The disclosure of your personal information to these third parties to assist us in providing these services may be considered a “sale” of personal information under the CCPA, or, the “sharing” of your personal information for purposes of “cross-context behavioral advertising.”
The following chart lists the categories of personal information we have sold or shared over the last 12 months and the categories of third parties to which we have sold or shared such personal information:
Category of personal information Categories of third parties to which we have “sold” or “shared” such personal information
Identifiers Advertising partners and advertisers;
Unaffiliated third parties for their advertising purposes;
Analytics providers
Demographic information Advertising partners and advertisers;
Unaffiliated third parties for their advertising purposes;
Analytics providers
Transactional information Advertising partners and advertisers;
Unaffiliated third parties for their advertising purposes;
Analytics providers
User-generated content Advertising partners and advertisers;
Analytics providers
Survey, research, or sweepstakes information Unaffiliated third parties for their advertising purposes;
Analytics providers
Internet network and device activity data Advertising partners and advertisers;
Analytics providers
Geolocation Advertising partners and advertisers;
Analytics providers
If you would like to opt out of our online disclosure such as through cookie and pixel technology of your personal information for purposes that could be considered “sales” for those third parties’ own commercial purposes, or “sharing” for purposes of targeted advertising, please go to the respective Sega property (e.g., sega.com, sega.co.uk, or the specific game website or app) and click on the “Your Privacy Choices” link in the footer of the website or settings menu of the app.” You must make this choice on each site/app on each browser/device you use to access the services. You must also renew this choice if you clear your cookies or your browser is set to do that. You can also submit a request to opt out of the use of your email address and other personal information related to that email address for targeted advertising purposes by emailing us at dataprivacy@segaamerica.com. Depending on your jurisdiction, you may be permitted to designate an authorized agent to submit such requests on your behalf. Please note that we do not knowingly sell the personal information of minors under 16 years of age without legally-required affirmative authorization.
Please note that if you have a legally-recognized browser-based opt out preference signal turned on via your device browser, we recognize such preference in accordance with applicable laws.
OTHER CALIFORNIA RIGHTS
California Civil Code Section 1798.83 (“Shine the Light”) permits our customers who are California residents to request, once per calendar year, the following information from us: (i) a list of the kinds of personal information that we have disclosed to third parties for direct marketing purposes during the preceding calendar year; and (ii) the names and addresses of all of the third parties that received personal information from us for direct marketing purposes during the preceding calendar year. For inquiries regarding our disclosure policy, please contact us by emailing dataprivacy@segaamerica.com. Requests must include “Shine the Light Rights Request” in the first line of the description and include your name, street address, city, state, and ZIP code.
California Business and Professions Code Section 22581 (“California Privacy Rights for Minor Users”) permits you, if you are a California resident under the age of 18, to view, correct or remove information provided by you or publicly posted by you. For inquiries regarding our disclosure policy, please contact us by emailing help@segaamerica.com. Requests must include “California Privacy Rights for Minor Users Request” in the first line of the description and include your name, street address, city, state, and ZIP code.
