“Shinsekai: Into the Depths” 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 play the game title made by Capcom, named “Shinsekai: Into the Depths” (“Shinsekai”) on your device.

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 who play Shinsekai.

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, 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? / How is your personal information used and shared?

Playing Shinsekai
When you play Shinsekai, game play data is stored in your iCloud account storage to sync your game progress across devices. If you are signed in to Game Center on your Apple device, Apple will receive your gameplay activity, including scores and achievements.

We do not receive or store this data on our servers.

The following game play data is stored in iCloud:

• • Save Data (including Game Center ID and UUID)

The following game play data is sent to Game Center:

• • Achievement ID

You may decline to store data in iCloud or to send data to Game Center. To turn off iCloud data storage, you must turn off iCloud in Apple Settings for Shinsekai. As a result, you will only be able to play in single player offline mode. To stop sending data to Game Center, you must sign out of Game Center in Apple Settings. As a result, you will not appear on leaderboards.

We do not store any personal information or gameplay data on our servers.

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.

The purpose of data usage;

• • To provide support and respond to emails, posts, questions, comments, requests and complaints.

We share your personal information with the following third parties where required for the purpose described above;

・Third party service providers and partners;
We share your personal information with certain third parties so that they can perform services on our behalf.

・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.

・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 limit our data collection and use to the persistent identifiers, as described in ‘What types of information do we collect about you? / How is your personal information used and shared?’ section, to support the internal operations of the game.

For how long do we keep your personal information?

• ・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.

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.

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: September 19, 2019