Privacy Policy
Privacy Policy for users in the United States of America
Updated: January 22, 2024
In this Privacy Policy, "DeNA", "we", "us", or "our" means DeNA Co., Ltd. and its subsidiaries.
Your privacy is important to DeNA. We designed our Privacy Policy to cover how we collect and use your information in connection with use of our mobile game software and media dedicated to that software ("Services"). By using our Services, you agree to our collection and use of your information, including your personal information, as described in this Privacy Policy. This Privacy Policy should be read together with our End-User License Agreement ("EULA").
So please take a moment to learn the five W's, the How, and other important matters about the information we collect and how we use it. If you have any questions, please contact us.
Contents
Please note that the short summaries set forth in the headers below are for clarification purposes only, and are detailed in the subsequent sections of this Privacy Policy.
- The What
Both non-personal information and personal information may be collected and used by us.
- The Why
The primary objective for our collection and use is to deliver and improve our Services.
- The When
When you provide information to us, use the Services, or register or connect with a third-party account system (such as the Nintendo Account) ("Account System") in connection with use of our Services.
- The How
By providing information to us directly, using the Services, or registering or connecting with an Account System in connection with use of our Services.
We may also use cookies and other electronic means to collect your personal information, but options are available to remove/disable certain cookies by the settings on your browser.
Services-related promotions may also be used by us; if you opt in, or as permitted by law, these services may include the sending of commercial electronic messages.
- The Who
We may disclose your information with persons who help us provide the Services, but only as necessary, and only to persons who are bound contractually to keep the information confidential, use it only to assist us in providing the Services, and protect using appropriate security safeguards.
Except only in special circumstances, we never transfer your personal information to advertisers or marketers for their own use without your separate consent.
We do not knowingly collect personal information from children under 13.
- The Where
In line with this Privacy Policy, your information may be processed in Japan and other countries, as necessary, where it may be subject to laws different than your home country.
- Changes to Privacy Policy
We may change this Privacy Policy, so please check for any updates.
- Your Choices
You have certain options with respect to how your personal information may be used or disclosed.
- Other Important Matters
Measures are taken to safeguard information received from you, and we keep your personal information only as long as necessary.
- Information Notice for California Residents & Privacy Rights
Certain provisions of this Privacy Policy are for California residents; if you are a California resident, please see additional information below.
The What
In the course of using our Services, you may provide us, directly and indirectly, with both personal and non-personal information. Personal information includes any factual or subjective information that can be used, on its own or in combination with other information, to identify you as an individual, and might include your name, phone number, pictorial representation, email address, postal address, opinions, comments, age, etc. Non-personal information is information that does not permit direct association with you, including personal information which has been aggregated with other users' information such that it can no longer be attributed to any individual. Certain non-personal information would be considered a part of your personal information if it were combined with other identifiers (e.g., combining your zip or postal code with your street address) in a way that enables you to be identified. But the same pieces of information are considered non-personal information if they are taken alone or combined only with other non-personal information (e.g., your viewing preferences), provided the information cannot otherwise be linked or attributed back to you as an identifiable individual.
The Why
Our primary objective in collecting your information is to provide you with a superior and personally relevant user experience. To achieve this, your information may be used as follows or by requesting explicit consent where required by law:
- To help us develop, deliver (in accordance with the EULA), and improve our Services, including the following aspects of our Services:
- messaging and other communication to and with users
- the creation, updating, accessing, and maintaining of lists of friends or contacts
- transactions for and use of virtual currency and virtual items
- communication and user-interactive features
- for purposes of tracking achievements on game platforms
- where consent is necessary, the delivery and targeting of advertising in the Services
- tracking of advertisement fulfillment metrics in the Services
- authentication purposes
- recommending Services-related products or services of interest directly to you
- for market research purposes that support our efforts to deliver a more valuable service to our community of users
- to contact you with announcements, newsletters, and promotional materials related to our Services or to offer you opportunities to participate in surveys, contests, or sweepstakes (any of these a "Promotion") via our Services.
- to provide end-user support.
- to prevent and take measures against fraud, illegal activities, infringement of our rights or interests, or breaches of our EULA and this Privacy Policy.
- to send important notices, such as changes to our EULA, this Privacy Policy, or other Services-specific policies. Because this information is important to your interactions with us, you may not opt out of receiving these communications.
- to audit and analyze data for technical administration, to improve our Services, and for end-user communications.
The When
Your information is collected by us when you directly interact with our Services, including by filling out your user profile in our application, and otherwise through use of our Services via the device you use to access or use our Services ("Device").
Your information may also be made available to us when you register with any Account System for use of our Services and/or permit any Account System to share any of your information with us in connection with your use of our Services, including account ID, country, region, language and username, and when any changes are made to that information. By accepting an Account System's applicable terms, you agree for the Account System to make such information available to us on those terms.
When you use our Services, we collect information related to your Device as described in "The How" section below.
If you choose to participate in a Promotion, we may request that you provide us with personal information such as your name, email address or postal address in order to administer your participation in the Promotion.
The How
As already mentioned, we may collect information from you when you directly interact with our Services and otherwise indirectly through your access to or use of our Services. You may have certain options to control the use of these technologies -- see Your Choices.
Direct interaction may include such actions as creating a username, or creating a friends' list. It may also include the sending of invites to become "friends" for the purpose of entering a battle together. We may but are not required, to collect and store the information referred to in this paragraph.
We may also collect your information from third parties who provide it to us, including other users of our Services and, as noted above, any Account System you engage with related to our Services.
As is standard practice, we do use "cookies" in connection with the Services. A cookie is a small string of text placed on your Device. In addition to strictly necessary cookies that enable us to provide our Services (such as those that provide your Account System log-in status when that account ID is linked to functionality on the Services), we may use both performance-gauging and functionality-gauging cookies. Performance-gauging cookies reveal how you use the Services, for instance, which content is the most popular, how much time users are spending there, and what advertising is relevant to you, which helps us provide an optimized experience (we may engage third parties to carry out this analysis, and they may set their own "third party" cookies--see "The Who" for more). Functionality-gauging cookies enables us to remember certain choices you make in interacting with the Services, for instance, any geographic location, language, or fonts you choose, which helps us tailor the Services to your preferences. Neither performance-gauging cookies nor functionality-gauging cookies collect information in any way that personally identifies you.
Except for cookies strictly necessary to enable us to provide our Services, you have the option to disable cookies stored on your browser by changing the options in your browser to stop accepting cookies or to prompt you before accepting a cookie from the content you visit. If you do not accept cookies, you may not be able to view or use parts of our Services due to limited functionality. Some cookies we use may be stored using a web-browsing component other than a browser application--these cannot be disabled on your Device, but the information collected does not personally identify you, and does not permit tracking between Services.
Some of our Services, including messaging, may use "click-through URLs" linked to other content on our Services. We track this click-through data in aggregate to help us determine interest in topics, Services usability, and other measures of user engagement.
In using our Services, our servers record information sent from your Device such as device name, mobile carrier, operating system, application version, personal settings (such as language and advertising tracking settings), Internet Protocol ("IP") address, device and advertiser identifiers (such as IDFA, AAID), cookie identifier, network type, time zone, log information (such as site access history and information about how you interact with game) and usage information (such as game user ID, game data, game play related information (including payment amount), and crash log data).
UNLESS OTHERWISE SPECIFIED HEREIN, BY ACCESSING OUR SERVICES, YOU ARE CONSENTING TO THE USE OF COOKIES AND THE OTHER ABOVE TECHNOLOGIES UNDER THE TERMS OF THIS PRIVACY POLICY.
The Who
Our Responsibility for Our Collections
We will collect and use your information as explained in this Privacy Policy. As a user of our Services, we offer functions that allow you to use and create your own profile, invite other users into multi-user battle rooms, and send stamps/stickers to other users during battles.
Interaction with Other Users via Social Features
As mentioned in "The Why", social interaction may be a function that is offered as a part of our Services. You understand and agree that your profile may be viewable in the Services by other users if they enter your designated ID, used to become "friends" for purposes of entering a battle together in the Services. Such invitations are sent through the Services by entering the invitee's designated ID, which can only be communicated to other users outside of the Services. When your designated ID is entered, other users of the Services will be able to see your profile information, which may include your username, user level, avatar, favorite in-game assets, and last login time (users may choose to block others from seeing last login time). We are not responsible for the activities of other users or other third parties with whom you choose to provide your information or otherwise interact.
Persons to Whom We May Disclose Your Information
You agree that we may disclose your information as follows:
- To Third Parties for Industry Analysis and Advertising
You agree that we may disclose technical information related to your Device (such as IP address), aggregated non-personal information, and anonymous information with advertisers, ad networks, and analytics analysis entities ("Ad Entities") with whom we have strategic relationships, and Ad Entities may also be permitted to collect such information via cookies and other tracking technologies. This information may be used to undertake user trend analyses, demographic profiling and analytics, and to provide to you tailored and personalized ads and advertising (behavioral advertising). Notwithstanding the above, we will obtain your specific consent to collect such information from your Device using iOS 14 or its successor OS for the purpose explained herein. Please note, though, that some Ad Entities also act as Service Providers (defined below) for us, and in those cases we may disclose your information as explained below.
- To our Service Providers
Disclosure of your information may also occur where we engage or employ service providers, vendors, or other third parties to help us provide our Services (each a "Service Provider") (e.g., improvement of our Services' features, promotion and marketing, administration, analytics, customer service, cloud storage, hosting, and other related services), to provide the Services on our behalf, or to assist us in analyzing how our Services are being used. Our Service Providers may have access to your personal information only to perform these tasks on our behalf, and they are directed not to disclose or use your personal information for any other purpose, and to protect your information to a level reasonably comparable with the safeguards we use.
- To Certain Third Parties in Special Circumstances
In some instances, we may disclose information about you where legally permitted, including to law enforcement officials or private parties if we believe it is necessary or appropriate to respond to claims and legal process (including subpoenas), to protect the property and rights of DeNA or a third party, to protect the safety of the public or any person, or to prevent or stop activity we may consider to be, or to pose a risk of being, illegal, unethical, or legally actionable activity.
In other cases, for example, in connection with a merger, acquisition, reorganization, or sale of assets, or in the event of bankruptcy, we may sell or transfer some or all of our assets. In connection with such a transaction, we may transfer all of the information about you in our records, including personal information, to any successor entity.
Policy Not to Collect Personal Information from Children
We do not knowingly collect personal information from, or store personal information of, children under the age of 13. We will upon notice or discovery take all reasonable efforts to erase or destroy any such personal information that may have been collected or stored by us without our knowledge or consent.
The Where
You understand and agree that we may transfer your information to and process it in Japan and other countries outside of your country of residence. Such transfer could subject the user's personal information to foreign laws, which may provide different levels of protection than those in your home country.
Changes to Privacy Policy
We reserve the right to change, amend or modify this Privacy Policy at any time. If we change this Privacy Policy in a material way, we will give notice of that in the Services, on our website, and/or by email to any email address we may have for you at that time. Your use of our Services after we have changed the Privacy Policy will indicate your consent to the updated Privacy Policy.
Other Important Matters
Push and Local Notifications
Unless you indicated otherwise at installation or chose not to receive push and local notifications, we may send push and local notifications to your Device concerning updates, events, and special offers for our mobile games and other mobile applications of the Services installed on your Device. Please note that you have the option of deactivating push and/or local notifications by changing the settings of the game/application or of your Device.
Protecting Your Information
We take your privacy very seriously and employ reasonable administrative, physical, and electronic measures to safeguard information received from you and held by us against identity theft and unauthorized access or alteration. In addition, we will take reasonable steps to assure that third parties to whom we transfer any data will provide sufficient protection of your personal information. We do not and will not, at any time, request your credit card information, login password, or any national identification numbers in a non-secure or unsolicited communication (e.g., via e-mail, telephone, or mobile device). We will not keep your personal information any longer than needed for the purpose it was collected or than is necessary for legal or legitimate business purposes.
We will make any legally required disclosures of any breach of the security, confidentiality, or integrity of your unencrypted electronically stored "personal data" or "personal information" (as defined in applicable statutes on security breach notification) to you via email or conspicuous posting on our website in the most expedient time possible and without unreasonable delay, consistent with (i) the legitimate needs of law enforcement; or (ii) any measures necessary to determine the scope of the breach and restore the reasonable integrity of the data system.
Corrections, Deletions and Requests for Information
If you have any concerns with the way we collect and handle your personal information, or would like to correct or request that we delete such personal information held by us, please contact us. We will use commercially reasonable efforts to honor your request; please note, though, that at a minimum we may retain an archived copy of your records as required by law or to send necessary communications to you under this Privacy Policy. You understand that deletion of your personal information may result in you not being able to view or use portions of our Services which depend on such information.
Your Choices
For a Promotion you have opted into, you have the option to opt out at any time from participation in such Promotion and the receipt of any related communications by following unsubscribe instructions provided in the relevant communications, or by selecting not to receive communications from us where the relevant media service offers that option.
For more information, including possible options you may have, on the use of behavioral advertising by Ad Entities generally, see, e.g., the Digital Advertising Alliance(https://www.aboutads.info/), the Network Advertising Initiative(https://www.networkadvertising.org/choices/).
Facebook offers settings that may control what information Facebook uses about you or your device activity for advertising purposes. Login to Facebook and go to Settings > Ads > Ad Settings (web) or Ad Preferences > Ad Settings (app) for more information.
X (formerly Twitter) offers settings that may control what information X (formerly Twitter) uses about you or your device activity for advertising purposes. Login to X (formerly Twitter) and go to Settings > Privacy and safety > Personalization and data for more information.
Google offers settings that may control what information Google uses about you or your device activity for advertising purposes. To opt-out of personalized ads across the web and on Google search, go to Google Ad Settings.
Other Websites and Services
Our Services may contain links to other websites and online services or offers from third parties. For example, our Services may include offers from third-party advertisers or the ability to engage in transactions with such entities. If you choose to participate in offer-linked information requests or "click on" an advertisement or another third-party link, you may be directed to that third party's website or service and/or be prompted to provide personal information in connection with such activity.
The fact that we allow linking to a third-party website or service (including Account System, and optional mobile game recovery services) is not an endorsement or representation of our affiliation with that third party, nor is it an endorsement of such third party's privacy or information security policies or practices or their compliance with any laws. We do not exercise control over third-party websites or services, and this Privacy Policy does not apply to information you provide or collected by them, including Ad Entities. These other websites or services may place their own cookies or other tracking devices on your computer or mobile device, or collect data or solicit personal information from you. Other websites and services follow different rules regarding the use or disclosure of the personal information you submit to them. We encourage you to read the privacy policies or statements of the other websites and services you use and the terms of the offers in which you participate. You agree that we are not responsible for, nor will we be liable to you or any third party for, your interaction with such third parties or the information requests initiated by such third parties or the subsequent use, treatment, or dissemination of the information you provide to them.
To the extent that any of our mobile applications of the Services collect personally identifiable information, that is done only as strictly necessary to enable us to provide those Services (see The How, above), and this cannot be disabled by "do not track" or other mechanisms available via your mobile Device's browser.
Information Notice for California Residents & Privacy Rights
California residents may have additional rights and choices related to identifying information and other types of personal information.
This section covers how we collect and use your information in connection with the use of the mobile game software and media dedicated to that software and applies solely to California residents.
Summary of Information Practices
If you are a California resident, California law requires us to provide you with some additional information regarding how we collect, use, and disclose your "personal information" as defined in the California Consumer Privacy Act as replaced by the California Privacy Rights Act ("CCPA").
Categories of Personal Information We Collect and Disclose
Throughout our Privacy Policy, including "The What" and "The When" sections, we discuss in detail the specific pieces of personal information we collect from and about users.
Under the CCPA, we are also required to provide you with the "categories" of personal information we collect. The categories we collect are:
- Account credentials (for game play purposes) such as your username, and game user ID;
- Contact identifiers (for Promotion purposes) such as names, addresses, phone numbers, and email addresses;
- Characteristics or Demographics, such as your date of birth and gender;
- Commercial or transactions information, such as records of products or services you purchased, obtained, or considered;
- Device identifiers, including your device’s IP address and AD Id;
- Device information, including your device’s operating software and browser (e.g., type, version, and configuration), internet service provider, and regional and language settings;
- Internet or other network or device activity, such as browsing history or Services usage;
- Non-precise location data, such as location derived from an IP address or data that indicates a city or postal code level;
- Inferences drawn from any of the above information identified in this section;
- Payment information including your payment instrument number (such as a credit or debit card number), expiration date, and security code as necessary to process your payments;
- User-generated content, including content within any messages you send to us (such as feedback, questions, or survey responses) or publicly post on the Service;
- Precise location data, such as latitude/longitude, with your consent; and
- Audio information, such as customer service call recordings if you do not opt out.
We disclose all of above categories of personal information to:
- Our affiliates and subsidiaries;
- Our service providers, such as marketing and advertising services, providers of payment and accounting services, transactional support providers, and providers of technical services (e.g., data storage, security, and customer relationship management databases); and
- Other parties where required by law or to protect our rights.
For the categories of sources from which personal information is collected, see “The When” and “The How” sections, above.
For additional information regarding the categories of third parties to whom information is disclosed, see “The Who” section above.
How We Use These Categories of Personal Information
We and our service providers may use the categories of personal information we collect from and about you for the following business purposes and commercial purposes (as those terms are defined in applicable law):
- Our or our service provider's operational purposes;
- Auditing consumer interactions on our site (e.g., measuring ad impressions);
- Detecting, protecting against, and prosecuting security incidents and fraudulent or illegal activity;
- Bug detection and error reporting;
- Providing the Services (e.g., account servicing and maintenance, customer service, advertising and marketing, analytics, and communication about the Services);
- Improving our existing Services and developing new services (e.g., by conducting research to develop new products or features);
- Other uses that advance our commercial or economic interests;
- Other uses about which we notify you.
Examples of these types of uses are discussed in "The How" section of this Privacy Policy. We may also use the categories of personal information for compliance with applicable laws and regulations, and we may combine the information we collect ("aggregate") or remove pieces of information ("de-identify") to limit or prevent identification of any particular user or device.
Data Retention
We retain the categories of personal information we collect from and about you in accordance with our internal retention policies no longer than the period reasonably necessary for each purpose described in “The Why” section.
Sale or Share of Personal Information
We do not sell information as that term is traditionally understood. However, some of our disclosures of personal information may be considered a “sale” or “share” as those terms are defined under the CCPA. A “sale” is broadly defined under the CCPA to include a disclosure for something of value, and a “share” is broadly defined under the CCPA to include a disclosure for cross-context behavioral advertising. We collect, sell, or share the following categories of personal information for commercial purposes: contact identifiers, characteristics or demographics, user-generated content, device identifiers, device information, internet activity, non-precise geolocation data, and inferences from any of the above. The categories of third parties to whom we sell or share your personal information include, where applicable, vendors and other parties involved in cross-context behavioral advertising. For details on your rights regarding sales and shares, please see the Right to Opt-Out of Sales and Shares section below.
Some of the personal information we collect may be considered sensitive personal information under the CCPA. For example, account information and precise location information. We collect, use, and disclose such sensitive personal information only for the permissible business purposes for sensitive personal information under the CCPA or without the purpose of inferring characteristics about consumers. We do not sell or share sensitive personal information.
Please note that we also do not knowingly sell and/or share the personal information of minors under 16 years of age without legally-required affirmative authorization.
California Privacy Rights
If you are a California resident, you may have certain rights. California law may permit you to request that we:
- Allow you to exercise your right to know what personal information we have collected about you, including the categories of personal information, the categories of sources from which personal information is collected, the business or commercial purposes for collecting, selling, or sharing personal information, the categories of third parties to whom we disclose personal information, and the specific pieces of personal information we have collected about you.
- Delete certain information we have about you.
- Correct inaccurate information we have about you.
You have the right to not be discriminated against (as provided for in applicable law) for exercising certain rights. Certain information may be exempt from such requests under applicable law. For example, we need certain types of information so that we can provide the Services to you and for compliance with applicable law. If you ask us to delete certain information, you may no longer be able to access or use the Services.
If you would like to exercise any of these rights, please contact Customer Support at [support@pokemonmasters-game.com] or via the Pokémon Masters application by going to the Poryphone Menu in the application, and tapping on [Other] -> [Customer Support] -> [Inquiries] -> [Making an Inquiry]. If you have an account with us, we may require you to use the account to submit the request. We will confirm receipt of your request within 10 business days and respond to your requests within 45 days.
You can also designate an authorized agent to make a request on your behalf. To do so, except with regards to your rights to opt-out of the sale or sharing of your personal information, you must provide us with written authorization or a power of attorney, signed by you, for the agent to act on your behalf. In all cases in which you (or your authorized agent) make a request to exercise your CCPA rights, you will be required to verify your identity directly with us, which may include, verifying your identity through contacting us through the Services via your mobile device and/or verifying certain game play or historical information regarding your use of the Pokémon Masters application. If you are unable to verify your identity, we will be unable to respond your requests.
To opt-out of sales or shares, as those terms are defined under CCPA, or the processing of information for targeted advertising purposes, click here. Please note that when you submit an opt-out we do not know who you are within our systems, and your opt-out will apply only to information collected from tracking technologies on the specific device from which you opt-out. If you use a different device, you will need to reconfigure your settings. If you want the opt-out to apply to information we have about you in our systems, such as your email address, please contact us at [support@pokemonmasters-game.com]
California’s Shine the Light law permits those of our customers who are California residents the right to request (i) a list of the categories of personal information disclosed by us to third parties during the immediately preceding calendar year for those third parties’ own direct marketing purposes; and (ii) a list of the categories of third parties to whom we disclosed such information. To make such a request, please contact us and specify that you are making a “California Shine the Light Request.” We may require additional information from you to allow us to verify your identity and are only required to respond to requests once during any calendar year.
If you are a California resident under 18 years old and registered to use the Service, under California’s Online Eraser Law, you can ask us to remove any content or information you have publicly posted on the Service. To make a request, please write to us at the email address set out in the Contact Us section above with “California Under 18 Online Eraser Request” in the subject line, and tell us what you want removed. We will make reasonable good faith efforts to remove the post from prospective public view, although we cannot ensure the complete or comprehensive removal of the content and may retain the content as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements.
Contacting Us
If you have any questions, inquires, requests, trouble accessing this policy, or complaints concerning this Privacy Policy or our information collection practices, please contact us at [support@pokemonmasters-game.com] addressed to "App Specialist" or by post:
Attn: App Specialist, DeNA Customer Support Center,
2-24-12 Shibuya, Shibuya-ku, Tokyo
150-6140 JAPAN.