Capcom Games Privacy Policy
(Console and PC games)

About us

We are Capcom Co., Ltd, with a registered address of 3-1-3 Uchihirano-machi, Chuo-ku, Osaka 540-0037, Japan (“Capcom”, “we”, “us” and “our”). This privacy policy explains how we handle the personal information of individuals (“you”) in relation to the use of our game services (console and PC games) as provided by Capcom.

Table of Contents

This privacy policy is divided into the following sections:

• • 1. What is personal information?
• • 2. What types of information do we collect about you?
• • 3. What is the purpose of use of personal information?
• • 4. Provision of personal information to a third party
• • 5. What is the legal basis for handling personal information?
• • 6. Children under the age of 16
• • 7. Transferring personal information outside the EEA
• • 8. Where and for how long do we store personal information?
• • 9. What are your privacy rights?
• • 10. What kinds of security measures do we take to safeguard your personal information?
• • 11. What are the provisions that apply to users who are California residents?
• • 12. How can you ask questions, or send us comments, about this privacy policy?
• • 13. How will you know if we amend this privacy policy?

1. What is personal information?

In this privacy policy, "personal information" means any information that directly or indirectly identifies an individual. For example, a name, user name or IP address.

2. What types of information do we collect about you?

We may collect the following types of personal information in relation to your use of our game services.

• • a. Information, such as your ID that is provided by us, your platform ID (user identification provided by a platform provider of games), and other information that identifies you as a player.
• • b. Information related to the operation environment of our games, such as information about your computer, device, software, etc.
• • c. Information of the country or region where you play our games and information related to your activities within our games.
• • d. Log files and crash reports, and other similar information.
• • e. Content of your inquiry.
• • f. Other information that we clearly specify prior to the collection of information.

3. What is the purpose of use of personal information?

We use the personal information that we collect for the following purposes:

• • a. To provide and improve our game services (including fixing bugs and preventing cheating or nuisances in our games).
• • b. To conduct statistical research and to analyze data with the aim of improving our services, including development of new features and even better games.
• • c. To deliver information on the products and services provided by us or a third party.
• • d. To respond to your inquires and to provide you with our support service.
• • e. To provide updates and information necessary for you, such as security alerts and support information.
• • f. To prevent infringement of copyrights and other rights.
• • g. For other purposes that are explained to you each time when we collect personal information.

4. Provision of personal information to a third party

We share your personal information with the following third parties:

With whom do we share your personal information?	Why do we share it?
Our partners and outsourcing contractors	We delegate the handling of personal information to our subsidiaries, affiliated companies, and other companies within the scope necessary for the fulfillment of the purpose of use provided in this privacy policy.
Service providers of game engines	Some third-party game engines that we use in our games may collect personal information about you. To find out more about what they collect and how they use and collect your personal information, please visit their websites and read their privacy policies.
Third parties requiring information for legal reasons	We share your personal information with others if the law requires us to, or if we think it is necessary to comply with the law. We may also share your personal information if we need to do so to protect or defend our legal rights, or those of others.
Third party investigators, authorities or law enforcement bodies	We share your personal information to investigate and protect our users from fraudulent, abusive, inappropriate, or unlawful behavior.
Potential buyers or investors	If we intend to sell our business, we may share your personal information with a potential buyer or an investor.

We do not sell any personal information to a third party for business or commercial purposes.

5. What is the legal basis for handling personal information?

We will only process your personal information when we have a legal basis to do so. Our legal basis are as follows:

• a) Contract. When we need to use your personal information to fulfill our obligations in relation to the contract you have with us (for example when you purchase one of our games or when you play our games); or
• b) Legitimate Interests. When it is in our legitimate interests to use your personal information. For example, it is in our legitimate interests to use your personal information in connection with our games, to improve our games, to ensure that our games are secure, to tell you about changes to our games, to tell you about new services or products we are offering, for business reasons (for example to develop our business or if we are thinking of selling our business), to tell you about offers or promotions we are running, or for operational purposes; or
• c) Legal Obligation. When we need to handle personal information to comply with a legal obligation.
• d) Consent. Sometimes we may ask for your consent to use certain types of personal information (for example, by asking you to tick an online box). Under these circumstances, your consent will be the legal basis for handing your personal information. If you have provided consent, you may withdraw it at any time. You may do this where we give you the opportunity to do so, or by contacting us using the contact details below. For example, we may ask for your consent to pass your personal information to third parties who may send you information about products, services or offers you may be interested in.

6. Children under the age of 16

If you are under the age of 16, you must speak to a parent or someone who has parental responsibility for you, so that you both understand this privacy policy and understand how we will use your personal information.

We will not handle any personal information of any children under the age of 16 based on their consent. If we discover that a child under the age of 16 has consented to the handling of their personal information without the permission of a person who has parental responsibility, we may delete their personal information. If you are a parent or guardian and discover that your child under the age of 16 has consented to the handling of their personal information then you may alert us via email using the contact details below and request that we start the process of deleting that child's personal information.
We do not sell the personal information of any user while recognizing that the user is under the age of 16.

7. Transferring personal information outside the EEA

Whenever we transfer your personal information out of the EEA and the UK, we will comply with applicable data protection law. We will undertake an international transfer in accordance with the mechanism prescribed below:

• • The transfer of your personal data is to a country that has officially been deemed to provide an adequate level of protection for personal data by the European Commission.
• • We may use specific contracts approved by the European Commission which give personal data the same protection it has in Europe (called the “EU Model Clauses”).

In addition, we may transfer your personal information internationally in the case of the following:
We may occasionally transfer your personal information outside the EEA and the UK if it is necessary for the establishment, exercise or defence of legal claims, or if the transfer is necessary either for the performance of a contract we have with you, or for the performance of a contract we have with a third party if that contract is in your interests.

8. Where and for how long do we store personal information?

We will store your personal information that we collect in either of the following places:

• • A server in Japan managed by Capcom.
• • A server in Japan or in the U.S.A. managed by a cloud service provider contracted by Capcom.
• • A server in the U.S.A. managed by a cloud service provider contracted by Capcom U.S.A., Inc. which is commissioned by Capcom.

Notwithstanding the above, if there is a separate description concerning the country and/or region where the information is stored in each game, such description shall take precedence.

We will retain your personal information for the term necessary for us to achieve the purpose of use. However, we may continue to store the information in processed form in which an individual is not identifiable.

9. What are your privacy rights?

You have the following rights in regarding your personal information:

• • Right to access. You have a right to access any personal information we hold about you. You can ask us for a copy of your personal information, confirmation as to whether your personal information is being used by us, details about how and why it is being used, and details of the safeguards which are in place if we transfer your information outside of the EEA or the UK.
• • Right to update your information You have a right to request an update to any of your personal information which is out of date or incorrect.
• • Right to delete your information. You have a right to ask us to delete any personal information which we are holding about you in certain, specific, circumstances. You can ask us for further information on these specific circumstances by contacting us, however it may not apply in circumstances where there exists any other legal basis for the handling (for example in the case where we need to use such personal information in order to fulfill our responsibilities under a contract between you and Capcom).We will pass your request onto other recipients of your personal information unless that is impossible or involves disproportionate effort. You can ask us who the recipients are by contacting us.
• • Right to restrict use of your information. You have a right to ask us to restrict the way that we process your personal information in certain specific circumstances. You can ask us for further information on these specific circumstances by contacting us. We will pass your request onto other recipients of your personal information unless that is impossible or involves disproportionate effort. You can ask us who the recipients are by contacting us.
• • Right to object. In relation to the handling of personal information on the basis of our, or another person’s, legitimate interest, you have the right to protest and ask us to discontinue the handling of your personal information.

10. What kinds of security measures do we take to safeguard your personal information?

• We have technical, administrative, and physical security measures in place to protect, in the best possible manner, personal information from unauthorized access and improper use.

11．What are the provisions that apply to users who are California residents?

Any matters not stipulated in this privacy policy related to the personal information of users who are California residents and to whom this privacy policy applies are subject to the following:

This chapter is established pursuant to the California Consumer Privacy Act of 2018 (“CCPA”).
This chapter applies strictly to California residents and supplements matters on additional disclosures and rights for California residents with regard to the method of handling personal information provided by users in relation to the use of our game services (console and PC games). For more information on the supplement to additional disclosures and rights for California residents related to the overall personal information handled by us, including the above-mentioned personal information, please refer to the Privacy Policy for California Residents.
We will update this Privacy Policy from time to time as appropriate. This Privacy Policy was last updated on October 24, 2022.

Collection and Use of Personal Information

Depending on how you interact with us and use our services, we may collect, or have collected within the preceding twelve (12) months, certain categories of personal information. The table below describes the categories of personal information collected; the categories of sources from which such personal information is collected; and the purposes for which such personal information is collected and may be used. We do not necessarily collect each item of personal information specified in each category below; rather, the table reflects our good faith attempt to describe, to the best of our knowledge, the categories of personal information that may be collected and their respective sources.

Categories of personal information	Sources of personal information	Purposes for use
Identifiers Examples: • Information, such as your ID that is provided by us, your platform ID (user identification provided by a platform provider of games), and other information that identifies you as a player.	• By using our game services and by contacting us individually through the use of the online form	a. To provide and improve our game services (including fixing bugs and preventing cheating or nuisances in our games). b. To conduct statistical research and to analyze data with the aim of improving our services, including development of new features and even better games. c. To deliver information on the products and services provided by us or a third party. d. To respond to your inquires and to provide you with our support service. e. To provide updates and information necessary for you, such as security alerts and support information. f. To prevent infringement of copyrights and other rights. g. For other purposes that are explained to you each time when we collect personal information.
Device Information and Device Identifiers Examples: Information related to the operation environment of our games, such as information about your computer, device, software, etc.
Country/region where a game is played and activities while a game is played Examples: • Progress status of a game • Playing time in a game
Error logs and crash reports
Content of your inquiry
Other information that we clearly specify prior to the collection of information

Disclosure of Personal Information

Depending on how you interact with us and use our services, as well as the nature of our business needs and operations, we may, from time to time, disclose your personal information for a business purpose, and/or “sell” such information to third parties. However, we do not sell personal information as most people might typically understand that term. Rather, we allow certain third-party partners and providers to collect information about our consumers directly through our services, for purposes of analyzing and optimizing our services; delivering ads; providing content and ads that are more relevant to consumers; measuring statistics and the success of ad campaigns; and detecting and reporting fraud. In case and to the extent this practice is interpreted as a “sale” as such term is defined by the CCPA, please see the link below for more information, including how to exercise your rights to opt-out of cookies, analytics and personalized advertising.

< https://www.capcom-games.com/en/legal/privacy-policy/#03>

In the last twelve (12) months, we have not sold personal information.

Your California Privacy Rights

As of January 1, 2020, the CCPA grants California residents with the certain privacy rights which are set forth below.

Right to Know
• You have a “Right to Know” what personal information we have collected, used, shared, or sold about you, and why we collected, used, shared, or sold that information. You may request, up to two times during any twelve (12) month period, that we disclose to you: the categories and specific pieces of personal information that we have collected about you; the categories of sources from which your personal information has been collected; the business and/or commercial purposes for which we have used your personal information; the categories of personal information that we disclosed or sold to a third party; and the categories of third parties with whom we have shared your personal information and the business or commercial purpose for selling your personal information, if applicable.

To exercise your Right to Know, please submit a request via email to privacyinfo@capcom.com and follow our instructions.

Right to Delete
• Your “Right to Delete” enables you to request that we delete personal information we collected from or about you and to tell our service providers to do the same. However, there are some reasons we may not be able to fully address your deletion request. These reasons include: if we cannot verify your request or we need to complete a transaction for you, provide you with a reasonably anticipated product or service, or for certain warranty purposes. We may also be unable to comply with your request to delete your information if your information is necessary for us to: debug, repair errors and detect security incidents; detect and protect against fraudulent, malicious and illegal activity; exercise our rights; comply with a legal obligation; etc.

To exercise your Right to Delete, please submit a request via email to privacyinfo@capcom.com and follow our instructions.

Right to Opt-Out
• You have the “Right to Opt-Out” from any “sale” of your personal information by us to third parties, as such term is defined by the CCPA.
We do not sell your personal information, as that term is defined based on our understanding of the CCPA and its implementing regulations. We have not sold any personal information to third parties for a business or commercial purpose in the 12 months prior to the effective date of this Privacy Policy. We do not share personal information with third parties for the business and commercial purposes, including without limitation advertising and marketing based on Users’ online activities over time and across different sites, services and devices.

Cookies, Analytics and Personalized Advertising
• As noted above, we do not “sell” personal information as most people would typically understand that term. However, we do allow certain third-party partners and providers to collect information about consumers directly through our services for purposes of analyzing and optimizing our services and ads, providing content and ads that are more relevant, measuring statistics and the success of ad campaigns, and detecting and reporting fraud. To the extent this practice is interpreted to constitute a “sale” under the CCPA, please see the URL below for more information including how to exercise your rights to opt-out of cookies, analytics and personalized advertising.

< https://www.capcom-games.com/en/legal/privacy-policy/#03>

Sale of Personal Information to Consumers under 16 Years of Age

We do not knowingly sell the personal information of consumers under 16 years of age.

Right to Nondiscrimination

• We will not deny, charge different prices for, or provide a different level or quality of goods or services if you choose to exercise your privacy rights conferred by the CCPA.

Verifying your Identity When You Choose to Exercise Your Rights

• • Should you choose to exercise any of your California privacy rights, we will need to verify your identity – including requesting personal information from you – for security purposes.
• • If you have an online account provided by us, logging into your account will serve to verify your identity and request. However, we may request additional information if we believe your account has been compromised. If you do not have an account provided us, or if we have reason to suspect that the security of your account is compromised, then we will request additional information from you to match with our existing records to verify your identity, depending on the nature of the request and the sensitivity of the information sought.
• • Once we have verified your identity (and your agent, as applicable), we will respond to your request as appropriate. If we are unable to complete your requests, we will provide you with information setting forth the reasons why we could not comply with your request.

Authorized Agents

• You may also designate an agent to make requests to exercise your rights under the CCPA as described above. We will take steps both to verify the identity of the person seeking to exercise their rights as listed above, and to verify that your agent has been authorized to make a request on your behalf by requesting a signed written authorization or a copy of a power of attorney.

Contact Information

If you have any questions or requests in connection with this Privacy Policy, please contact below.

Email: privacyinfo@capcom.com

Postal Address: Personal Information Contact, Capcom Co., Ltd, 3-1-3 Uchihirano-machi, Chuo-ku, Osaka 540-0037, Japan

12. How can you ask questions, or send us comments, about this privacy policy?

If you have any complaints, queries or questions about how we use your personal information, you may contact us using the following contact details:

Email: privacyinfo@capcom.com

Post: Personal Information Contact, Capcom Co., Ltd, 3-1-3 Uchihirano-machi, Chuo-ku, Osaka 540-0037, Japan

We will then get in touch with you to see how we can help. If you have a complaint about how we use your personal information, we would always prefer you to contact us first. However, you may also make a complaint to the relevant data privacy regulator if you wish to do so. Please let us know if you are unsure about how to get in touch with the data privacy regulator.

We have a data protection officer who is responsible for matters relating to personal information. You may contact our data protection officer using the following details:

Email: dpo@capcom.com

Post: Personal Information Contact (DPO), Capcom Co., Ltd, 3-1-3 Uchihirano-machi, Chuo-ku, Osaka 540-0037, Japan

If you need to contact our data protection officer within the EEA, please refer to the following contact information:

Capcom Entertainment Germany GmbH
Borselstraße 20,
22765 Hamburg,
Germany

Email: ceg.gdpr@capcom.com

13. How will you know if we amend this privacy policy?

We may amend this privacy policy from time to time. We will notify you when this privacy policy has been updated on our website. However please also review this privacy policy periodically so that you understand how your personal information will be used.

Established on: October 1, 2018
Revised on: May 9, 2019
Revised on: October 24, 2022