Koei Tecmo Games Co., Ltd.（以下也称 “我们”、“Koei Tecmo”）非常重视您的隐私，并致力于以透明、公平和安全的方式处理您的个人信息。当您使用Apple Arcade平台名为《三国志 HEROES》的游戏（以下简称“本服务”）时，我们会收集、使用并与第三方共享关于您的某些个人信息。
本隐私政策旨在向您介绍我们如何、为何以及基于什么理由收集、使用和共享您的个人信息，以及您可以就您的个人信息行使的法律权利。使用本服务，即表示您同意本隐私政策以及我们按其所述对您的个人信息的收集、使用和共享等活动。如果您不同意本隐私政策，请卸载并停止使用本服务。
根据您所居住或所在的国家/地区，可能适用特定国家/地区的法律法规，详情请参照附件。如果本隐私政策的正文条款与附件存在冲突，在冲突存在的范围内，将以附件内容为准。
- 附件：EEA (European Economic Area) and the UK
- 附件：U.S.
请注意，下文第2、3和10节中的“个人信息”包含日本《个人信息保护法》所定义的“个人信息”。
我们可能会不时修改、增加或删除本隐私政策的部分内容。我们将通过电子邮件、在官方网站上公布或在本服务内通知的方式通知您任何此类更新。
本隐私政策由KOEI TECMO GAMES CO., LTD.发布，KOEI TECMO GAMES CO., LTD.属于 GDPR所规定的负责人并提供本服务的过程中负有收集和使用您的个人信息的责任。
出于本隐私政策第3节所述的目的，我们可能会向您所在国家/地区以外的国家/地区（包括日本）传输个人信息，我们会采取适当的保护措施来传输您的个人信息。
本服务不针对或意图面向13岁以下的人群。在允许您使用某些服务之前，我们可能会收集您的年龄信息。如果我们发现无意中收集了岁以下儿童的个人信息，我们将采取一切合理措施，删除此类个人信息及其相关记录。
如果您对我们处理您个人信息的方式存有异议，您可以向相关个人信息保护监督机构投诉。
如需了解更多信息或进行询问，请联系：
隐私政策联系人
KOEI TECMO HOLDINGS CO., LTD.
1-18-12 Minowa-cho, Kouhoku-ku,
Yokohama, 223-8503, Japan
电子邮箱：privacy@koeitecmo.co.jp
Effective date: [2025/1/9]
Last updated: [2025/1/9]
This Exhibit (a) applies to the processing of your personal data by Koei Tecmo if you are located or residing in the EEA (European Economic Area) or the UK and refers to the GDPR and the UK GDPR (collectively, the "GDPR").
This Exhibit includes information about your data protection rights, including a right to object to some of the processing which we carry out. More information about your rights, and how to exercise them, is set out in "3. Your rights" below.
We process your personal data pursuant to the following legal basis for the purposes stated in 3.1 of this Privacy Policy.
| When processing is necessary for the performance of a contract (GDPR Article 6, Paragraph 1, Item (b))
- to provide customer support of your choice;
- to perform our contractual obligations towards you with respect to our Services.
| When processing is necessary for pursuit of legitimate interests (GDPR Article 6, Paragraph 1, Item (f))*
- to reply to user questions or queries,
- to provide customer support and resolve problems relating to the Services,
- to exercise or defend legal claims; or
- to fulfill our obligations under applicable laws and regulations of countries other than countries in the EEA and the UK and respond to requests of government authorities.
*For details of the balancing test for legitimate interests (GDPR Article 6, Paragraph 1, Item (f)), please contact us using the contact details stated in "4. Contact details of representatives and data protection officers" below.
| When processing is necessary for compliance with a legal obligation (GDPR Art. 6(1)(c))
- to fulfil our obligations under applicable laws and regulations of the EEA and the UK.
If we transfer personal data to areas other than the EEA (European Economic Area) or the UK, we (i) will be based on an adequacy decision (GDPR Article 45) in the countries where the adequacy decision is adopted or (ii) will take appropriate protection measures by executing the standard data protection clauses approved by the European Commission (GDPR Article 46, Paragraph 2, Item (c) and Paragraph 5) or the standard data protection clauses approved by ICO (UK GDPR Article 46, Paragraph 2, Item (d)) with the party receiving personal data in the countries where an adequacy decision is not adopted.
Please see here with respect to the details of the adequacy decision to Japan.
Please contact us using the contact information stated in 11 of the Privacy Policy if you wish to receive a copy of the documents relating to those protection measures.
You have the following rights.
- Obtaining information regarding data processing: You have the right to obtain from us all necessary information regarding our processing of data concerning you (GDPR Article 13 and Article 14).
- Access to personal data: You have the right to obtain confirmation from us as to whether personal data concerning you is being processed, and, where that is the case, to access the personal data and certain relevant information (GDPR Article 15).
- Rectification and erasure of personal data: You have the right to have us rectify inaccurate personal data concerning you without undue delay and have incomplete personal data completed by us (GDPR Article 16). You also have the right to have us erase personal data concerning you without undue delay when certain conditions are met (GDPR Article 17).
- Restricting processing of personal data: You have the right to restrict our processing of personal data concerning you when certain conditions are met (GDPR Article 18).
- Objection to processing of personal data: You have the right to object to our processing of personal data concerning you when certain conditions are met (GDPR Article 21, Paragraph 1).
- Objection to direct marketing: You have the right to object at any time to our processing of personal data for direct marketing (GDPR Article 21, Paragraph 2).
- Data portability: You have the right to receive personal data concerning you in a structured, commonly used, and machine-readable format and to transmit that data to another controller without hindrance from us, when certain conditions are met (GDPR Article 20).
- Right to withdraw your consent: You have the right to withdraw your consent at any time by the means separately specified at the time we obtain your consent. However, your withdrawal of consent does not affect the lawfulness of processing conducted based on your consent before the withdrawal.
- Freedom from automated decision-making: When certain conditions are met, you have the right not to be subject to automated (meaning without human involvement) decision-making that produces legal effects or significant effects on you (GDPR Article 22).
- Regarding our processing of your personal data, you may lodge a complaint with the relevant data protection supervisory authority of the member state where your habitual residence, your place of work, or the place of the alleged infringement, is located (GDPR Article 77).
The contact details of representatives in the UK as well as our Data Protection Officer are as follows.
- Representative in the UK
Full name of company: Koei Tecmo Europe Ltd.
Name or title of data privacy manager: General Manager
Email address: privacy@koeitecmo.co.uk
Postal address: Unit 403a, The Spirella Building, Bridge Road, Letchworth Garden City, Hertfordshire, SG6 4ET
Telephone number: +44(0) 1462 476130
- Data protection officer
Full name of company: Koei Tecmo Games Co., Ltd.
Name or title of data privacy manager: Koinuma Hisashi
Email address: privacy@koeitecmo.co.jp
Postal address: 1-18-12 Minowa-cho, Kouhoku-ku, Yokohama, 223-8503, Japan
Effective date: [2025/1/9]
Last updated: [2025/1/9]
This Exhibit (a) applies to the processing of your personal data by Koei Tecmo if you are located or residing in the U.S..
This Exhibit includes information about your data protection rights, including a right to object to some of the processing which we carry out. More information about your rights, and how to exercise them, is set out below.
- information on what personal data we have about you and access to your personal data and other supplementary information.
- having your personal data rectified.
- having your personal data erased.
- having our processing of your personal data frozen.
- obtaining your personal data in a structured, commonly used and machine-readable format.
- not being subject to automated decision making and profiling.
- to request certain information regarding its disclosure of personal data to third parties for direct marketing purposes pursuant to Section 1798.83 of the California Civil Code via email described in Section11 with "California Shine the Light Request" in the subject line.
- to know what categories and specific pieces of personal data are collected about you. As such, you may submit a verifiable consumer request via email described in Section11 with "CCPA Information Collected" in the subject line.
- to know what personal data is used, sold, shared, or disclosed with third parties and to whom. You may submit a verifiable consumer request via email described in Section11 with "CCPA Information Shared" in the subject line.
- to opt-out of the sale or share sharing of your personal data by us to third parties at any time. You can submit a request to opt-out by submitting a verifiable consumer request via email described in Section11 with "Do Not Sell or Share" in the subject line.
- subject to statutory exclusions, to request that we delete the personal data and correct in accurate personal data that we have collected about you. You may submit a verifiable consumer request via email described in Section11 with "CCPA Information Deletion" in the subject line.
- to limit the use and disclosure of sensitive personal data that we have collected about you. You may submit a verifiable consumer request via email described in Section11 with "CCPA Information Limitation" in the subject line.