Privacy Policy Update:
May 9, 2019: " Where do we store the personal data collected based on the consent?" was added.

Capcom Games Privacy Policy

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 use the personal information of individuals (“you”) who use console and PC games made and/or published by Capcom.

We have a Data Protection Officer, whom you may contact either by email at dpo@capcom.com, or by post using the postal address above. If you wish to contact our Data Protection Officer by post, please address your letter to our “Personal Information Contact”.
About this privacy policy
The purpose of this privacy policy is to explain what personal information we collect, how we use it and with whom it is shared. This privacy policy applies to all users of our console and PC games.
What information does this privacy policy cover?
This privacy policy is divided into the following sections:
  • • What is personal information?
  • • What types of information do we collect about you?
  • • How is your personal information used and shared?
  • • What is our legal basis for using your personal information?
  • • Children under the age of 16
  • • For how long do we keep your personal information?
  • • We may transfer your personal data outside the EEA
  • • What are your privacy rights?
  • • What kinds of security measures do we take to safeguard your personal information?
  • • How can you ask questions, or send us comments, about this privacy policy?
  • • How will you know if we amend this privacy policy?
Your rights to object: You have various rights in respect of our use of your personal information, as set out in the ‘what are your privacy rights?’ section below. Two of the fundamental rights to be aware of are that:
  • • You may ask us to stop using your personal information for direct marketing purposes. If you exercise this right, we will stop using your personal information for this purpose; and
  • • You may ask us to consider any valid objections which you have to our use of your personal information where we process your personal information on the basis of our, or another person's, legitimate interest.
You can find out more information in the ‘what are your privacy rights?’ section below

What you need to do and your confirmation to us: Please read this privacy policy carefully to understand how we handle your personal information. By engaging with us in the ways set out in this privacy policy, including playing our PC and console games, you confirm that you have read the entirety of this privacy policy, as it applies to you.
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.
What types of information do we collect about you?
Playing our PC and console games
We may collect the following types of personal information from you when you play our PC and console games:
  • • Information about your location.
  • • Information such as your platform ID, your display name or other user identification.
  • • Technical information about the computer, device, and software you use to play our games, For example, we collect personal information about your IP address, your operating system and your browser.
  • • Telemetry and statistical data about your behaviour when you play our games. For example, we collect personal information about your progress within our games, how long you spend playing them, characters you select, how you interact with other players, and matchmaking times in multiplayer games.
  • • Log files and crash reports, and other similar information.
  • • Log files which record information about the technical events which take place when you play our games.
  • • Information we require to enable certain features of our games such as saving progress, in-game rankings, matchmaking with other users when you play multiplayer games, and information about the other users you have matched with.
  • • Information relating to your activities within our games, such as the amount of virtual currency you have and the features you have unlocked.
Digital rights management
For our PC games, we collect certain personal information, which we use for digital rights management purposes, including identifying and preventing individuals from using our games unlawfully.

Game engines
Some of the third party game engines we use in our games collect personal information about you, which they use for their own purposes. For example, Unreal engine collects personal information about events completed or actions taken within a game. We also obtain personal information from the game engines such as aggregated reports about game activity. To find out more about these game engines and how they collect and use your personal information you should visit their websites and read their privacy policies.

Games stores and digital distribution platforms
We may obtain personal information about you from online stores and digital distribution platforms. These third parties collect and use your personal information in various ways. They also use this personal information for their own purposes, which are covered by their own privacy policies. When you use third party games stores or digital distribution platforms you should read their privacy policies carefully so that you understand how they will use your personal information.

Dealing with your questions or complaints
If you contact us with questions or complaints we will collect your personal information to handle those question or complaints, including information about the nature of the issue, and your contact details.

In-game purchases
We collect your personal information if you make in-game purchases, including payment and purchase information. For example, if you buy costumes, skins, colours and other premium or unlockable features.
How is your personal information used and shared?
We use personal information we collect for the following purposes:
  • • To enable you to enjoy all the features within our games. For example, to enable you to match with other users when you play multiplayer games, save your progress, save and share your ranking, make in-game purchases for premium and unlockable content, enable gameplay replays, qualify for e-sports tournaments, and to select which servers you wish to play on.
  • • To develop and improve our games. For example, we use personal information to work out how we can reduce matchmaking times, fix bugs, and issue updates.
  • • To fix bugs and issue updates. For example, we use crash reports to understand the events leading up to a crash so we can try to prevent it happening in the future.
  • • To better understand our users. For example, we use technical information to get a better understanding of what platforms and devices our users use.
  • • To understand which new game features to develop.
  • • To let you know about important information. For example, we may contact you about updates, security alerts and provide you with support and administrative messages.
  • • To protect and enforce our legal rights and the rights of others. For example, we use your personal information for digital rights management to prevent individuals from using our games unlawfully.
  • • To detect and prevent cheating.
  • • For analytics purposes, including understanding more about who plays our games, which features they like and which features could be improved, and how we can make better games in the future.
  • • To provide support and respond to emails, posts, questions, comments, requests and complaints.
  • • To process any in-game purchases.
  • • To enforce any of Terms of Use that may apply, or our other policies or agreements.
  • • To investigate and protect individuals from fraudulent, abusive, inappropriate, behaviour.
  • • For other purposes, which are explained to you at the time, we collect your personal information.
We share your personal information with the following third parties:
With whom do we share your personal information? Why do we share it?
Third party service providers and partners We share your personal information with certain third parties so that they can perform services on our behalf. For example, we share personal information with Amazon Web Services, which processes certain personal information on our behalf. We also share your personal information with partners where we are working together in relation to particular games or projects relating to the purposes set out in this privacy policy.
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 wish to sell our business, we may need to share your personal information with a potential buyer or an investor.
Group companies We share your personal information with members of our group of companies where required for business operational reasons.
What is our legal basis for using your personal information?
We will only process your personal information where one of the following applies:
  • • We need to use your personal information to perform our responsibilities in relation to a contract you have with us (for example your purchase of one of our games, and when you play our games).
  • • 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.
  • • We need to process your personal information to comply with a legal obligation.
  • • Sometimes we may ask for your consent to use certain types of personal information (for example, by asking you to tick an online box). In these circumstances, your consent will be our legal basis for processing 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.
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 process 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 processing of their personal information without the permission of a person who has parental responsibility for them, 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 processing of their personal information then you may alert us via email using the contact details below and request that we start the process to delete that child's personal information.
For how long do we keep your personal information?
Type of data How long do we normally keep it?
Personal information we collect which enables you to use the features within our games (for example when your progress in a game is saved, or when we collect data in order to match you with other players in a multiplayer game). For so long as there is a possibility of you continuing to play the game.
Telemetry data, anti-cheat data, log files, crash reports, platform ID, display name, location data, data we obtain from game engines, and other technical information about your use of our games. Throughout the period you are using the game, and for a period of time afterwards, while it remains useful for us (for example, to develop new games).
Digital rights management data. For so long as the copyright subsists in a game.
Information which we obtain from game engines. For no longer than necessary for the purposes for which the personal information is processed.
Information which we obtain from game stores and digital distribution platforms. For no longer than necessary for the purposes for which the personal information is processed.
Questions or complaints, and other similar communications. Until the issue has been resolved, and potentially for a period after if we need to, to help protect our legal rights.
Information about in-game purchases. Throughout the period you are using the game, and for a period of time afterwards, while it remains useful for us (for example, as reference when developing new games)
Once we no longer need to keep personal information, we will delete it. However, sometimes, we may continue to hold data in anonymised form, which does not identify an individual (for example, we may retain aggregated data about many users, which does not identify a particular individual).
We may transfer your personal data outside the EEA
Whenever we transfer your personal information out of the EEA and the UK, we will comply with applicable data protection law. Some of the mechanisms we may choose to use when undertaking an international transfer are:
  • • 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”).
  • • Where we use providers based in the United States of America (the “US”), we may transfer data to them if they are part of the Privacy Shield which requires them to provide similar protection to personal data shared between the Europe and the US. If the provider is not EU-US Privacy Shield certified, we may use the EU Model Clauses.

Occasional and necessary transfers
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.
Where do we store the personal data collected based on the consent?
When we collect and store your personal information subject to your consent, regardless of your country of residence, we will store the information in the following places;
  • • A server in Japan managed by Capcom.
  • • A server in U.S.A. managed by a cloud service provider contracted 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 supersede.
What are your privacy rights?
You have the following rights in regarding your personal information:
  • Right of access. You have a right of access to 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 and 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 it remains necessary for us to retain it in relation to the purposes we collected it for (for example in some multi-player scenarios). 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 data portability. You have a right to ask us to provide your personal information to a third party provider of services. This right only applies where we use your personal information on the basis of your consent or performance of a contract, and where our use of your information is carried out by automated means.
  • Right to object. You have a right to ask us to consider any valid objections which you have to our use of your personal information where we process your personal information on the basis of our, or another person's, legitimate interest.
If you need help or wish to exercise any of the above rights or have questions about them, please contact us using the details below. We will consider all such requests and provide our response as soon as we can. Please note, however, that personal information may be exempt from such requests in certain circumstances, which may include needing to keep processing your personal information for our legitimate interests or to comply with a legal obligation. Please note that we may request you to provide us with information necessary to confirm your identity.
What kinds of security measures do we take to safeguard your personal information?
The security and confidentiality of your information is extremely important to us. We have technical, administrative and physical security measures in place to protect your personal information from unauthorized access and improper use. We also review our security procedures periodically to consider appropriate new technology and updated methods. But despite our best efforts, no security measure is ever perfect or impenetrable. Specific security measures we currently implement to prevent unauthorized physical or electronic access to users' personal information include the following:
  • • User data is stored behind a firewall to protect your data from unauthorized access or against loss, misuse or alteration.
  • • Data is stored in a secure physical environment (for example, behind locked doors).
  • • Data is stored in a database accessible to authorized employees on a need-to-know basis only.
  • • Users or employees must have a unique password before gaining access to user data.
  • • We use industry standard encryption technology when transferring or receiving sensitive personal information.
  • • We maintain written security policies to which all employees must adhere.
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, Capcom Co., Ltd, 3-1-3 Uchihirano-machi, Chuo-ku, Osaka 540-0037, Japan
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