PRIVACY POLICY

Updated April 1, 2024

1. Introduction

By browsing or using this website, you signify your assent to this KOEI TECMO AMERICA Corporation (“KOEI TECMO” or “we”) Privacy Policy (the “Privacy Policy” or “Policy”). If you do not agree to the terms and conditions set forth in this Privacy Policy, please do not use any KOEI TECMO site.

For your privacy, we do not collect or maintain data that personally identifies you without your consent or unless you provide such data voluntarily. Please read on to learn more about KOEI TECMO’s commitment to your privacy.

This Privacy Policy covers only websites administered by KOEI TECMO, and not those of our Parent Company, KOEI TECMO HOLDINGS CO., LTD., or any of its other international affiliates. This Policy does not apply to any information that may be collected offline via postal mail or other forms of communication.

2. What Information and Why We Collects

TECHNICAL INFORMATION AND TRAFFIC DATA

Every time a guest visits KOEI TECMO’s website, our server tracks technical information and traffic data. This tells us the domain name of your Internet Service Provider, your Internet Protocol address (a series of numbers which is unique to your computer), referral data (for example, the website you were looking at when you clicked to our site), as well as which web browser and computer platform you are using. KOEI TECMO may track and use this data for security purposes, to improve our website and to maintain the servers hosting our website.

PERSONAL INFORMATION

In order to give you a better online experience, KOEI TECMO may collect information about you, but ONLY if you provide it to us voluntarily. We may use the information you provide for the following purposes: 1) to send e-mail updates about KOEI TECMO products; 2) to respond to specific questions about KOEI TECMO products; 3) to protect the security and integrity of our website and servers; 4) to allow registration for the KOEI TECMO forum/discussion board; 5) to fulfill orders placed for goods and services in the event that KOEI TECMO launches an online store.

3. Email to Webmaster

In various locations on KOEI TECMO’s website, there are links for users who wish to send an email inquiry to our Webmaster. KOEI TECMO may collect the personal information in these email inquiries for the sole purpose of responding to them. In most cases, we delete emails after responding to them. However, we reserve the right to maintain such messages for security purposes.

4. Online Store

In the event that KOEI TECMO launches an online store, visitors who wish to buy goods and services may be asked to provide a valid credit card number and expiration date, name, billing and mailing address, phone number, and email address. KOEI TECMO may use such information in order to fulfill your purchase of goods and/or services.

5. Promotions

From From time to time, KOEI TECMO may hold promotions during which we award KOEI TECMO game-related products to our online guests. In order to register for a promotion, we may ask you to provide us with personally identifying contact information, such as full name, address, and e-mail address.

When you register for a promotion, we may ask if you wish to be contacted with more information about KOEI TECMO products. If you decline to receive more information about KOEI TECMO, we will discard all of your contact information at the end of the promotion. If you accept, we may maintain your email address for the purpose of sending information to you in the future; all other contact information will be discarded.

You may participate in KOEI TECMO promotions whether you choose to receive additional information about KOEI TECMO products or not.

6. Effects of Not to Provide Information

If you do not wish to submit personal information, you will not have access to some of the features of our website. You do not need to share personal information to browse our website.

7. Cookies and Other Passive Information Collection

When you interact with KOEI TECMO’s website, we collect Anonymous Information through automated technologies as described below. “Anonymous Information” means information that does not directly or indirectly identify, and cannot reasonably be used to identify, an individual person.

Cookies. A “cookie” is a small text file that is sent to your browser from a web server and stored on your computer’s hard drive or mobile device. KOEI TECMO may use cookies to track Anonymous Information about our users (e.g., user name, pages viewed, time spent on our website, and the websites visited just before and just after our website for statistical and market research purposes. We use cookies to gather information about our users’ browser activities. By modifying your browser preferences, you may have the option to reject all cookies, or limit the type of cookies you allow. Rejecting or limiting the type of cookies may, however, in limited instances prevent you from accessing certain features on our websites. Please refer to our Cookie Policy (https://www.koeitecmoamerica.com/cookies-policy/) for more details.

Log Files. Like most Internet services, we may also use log files on the server side to collect information from you. Your information held in log files includes your computer’s or mobile device’s IP (Internet Protocol) address, browser type, browser language, e-mail application, internet service provider, referring/exit web pages, computer platform type, date/time stamp, and user activity. The software enabling our services has associated log and temporary files that are stored on our servers. These files store your account information, preference settings, system notifications as well as other data necessary to enable you to use our website. Your information may also be collected in connection with regularly performed server backups.

Tracking Technologies. KOEI TECMO may utilize a variety of tracking methods to collect information from you, including, without limitation web beacons (also known as Internet tags, pixel tags and clear GIFs). Web beacons are small pieces of data that are embedded in images on the pages of websites to analyze the traffic patterns, such as the frequency users visit various areas of our website. Pixel tags may allow us to advertise more efficiently by excluding our current users from certain promotional messages or identifying the source of a new installation. These methods may involve collecting information directly from you or through another entity authorized by us to collect information on our behalf. We may also use these methods in HTML e-mails that we send our guests to determine whether the recipients have opened those e-mails or clicked on links in those e-mails. The information that we collect through tracking technologies is Anonymous Information.

The use of cookies, web beacons, or similar automated information collection technologies by third party advertisers is subject to their own privacy policies. Once you have clicked on an advertisement and have left our website, our Privacy Policy no longer applies and you must read the privacy policy of the applicable third-party advertiser to see how your information will be collected, stored and used as part of their service. Specifically, privacy choices you have made on the third-party site or platform will not apply to our use of the information we have collected directly from you or through our automated technologies.

Click Through URLs. Some of our services, including email messages, use “click-through URLs” linked to other content on our services. We track this click-through data to help us determine interest in topics and use of the services.

8. Who Collects Information

Information you submit to our website is collected by KOEI TECMO and is used only in the manner expressed above in this Privacy Policy.

9. Where Information Is Stored

When you submit personal information to KOEI TECMO, the information is housed in secure databases, equipment and servers located in the United States, the United Kingdom, or in other countries. The databases, equipment and servers we utilize may be owned by third party providers.

10. How We Share Information

We may disclose your personal information to service vendors and partners (including carriers and content providers) in connection with our provision of services. Such service vendors and partners may be located in countries other than your country of residence and provide such services as payment processing, data analysis, e-mail delivery, hosting (such as website hosting), order fulfillment, infrastructure and network storage, customer service, technical support, auditing, content licensing and promotional services.

KOEI TECMO may also disclose your information in the event that disclosure of information is required by law enforcement or other government officials in connection with investigation of fraud, intellectual property infringements, or other activity that is illegal or that may expose you or us to legal liability.

11. Opt Out Procedure

If you do not want to be contacted by KOEI TECMO or its service providers for marketing purposes, at no charge, you may opt out by using the “opt out” procedures described below. We will use our commercially reasonable efforts to comply with your request.

• You can send an email to Privacy@koeitecmoamerica.com;
• You can send mail to: at KOEI TECMO AMERICA Corporation, 831 Mitten Road, Suite 216, Burlingame, CA 94010. Mark envelopes ATTN: Customer Database; or
• You can call us at (650) 692-9080 between the hours of 9:30 am and 5:00 pm Pacific Standard Time

12. California’s Shine the Light law

Pursuant to Section 1798.83 of the California Civil Code, customers, prospective customers, and visitors of our website and users of our service who are residents of the State of California have the right to request certain information regarding its disclosure of Personal Information to third parties for direct marketing purposes. If you are a California resident and wish to request such information email us at Privacy@koeitecmoamerica.com with “California Shine the Light law” in the subject line.

13. California Consumer Privacy Act (“CCPA”)

If you are a natural person who is a California resident, you have the following rights;

• You have the right to know what categories and specific pieces of personal information are collected about you. As such, you may submit a verifiable consumer request via the following methods: email us at Privacy@koeitecmoamerica.com with “CCPA Information Collected” in the subject line.
• You have the right to know what personal information is sold, shared, or disclosed with third parties and to whom. You may submit a verifiable consumer request via the following methods: email us at Privacy@koeitecmoamerica.com with “CCPA Information Shared” in the subject line.
• You have the right to opt-out of the sale or sharing of your personal information to/with third parties. We, however, do NOT and will not sell or share your personal information to third parties, except in the case of Section 10, at this point.
• Subject to statutory exclusions, you have the right to request that we delete the personal information and correct in accurate personal information that we have collected about you. You may submit a request for deletion via the following methods: email us at Privacy@koeitecmoamerica.com with “CCPA Information Deletion” in the subject line. You may not have access to some of the features of our website after deletion of the collected personal information.
• You have the right not to be discriminated against for exercising your rights under the California Consumer Privacy Act of 2018 (CCPA).
• We may require authentication of your identity that is reasonable in light of the nature of the personal information requested. If you would like to designate an authorized agent to make a request under the CCPA on your behalf, you must provide your valid power of attorney to us. We may require further authentication of you or the agent, if deemed necessary.

14. Access to Information

Yes. If you would like to view or correct information that you previously submitted to our customer database, you may access it by contacting us at the email address, phone number or postal mail address set forth in the Contact Us section at the very bottom of this Privacy Policy.

15. No Response to “Do Not Track”

KOEI TECMO does not respond to DNT (Do Not Track) signals.

16. Privacy Policy of Third Party Sites

No. While visiting the KOEI TECMO website, you may be directed to a third-party website for which we are not responsible. We cannot guarantee that those websites will guard your privacy to the same high KOEI TECMO standard. Please read the privacy statement of any third-party website before you submit any personal information.

17. Users Outside of the United States

KOEI TECMO is a California corporation and its business operations are primarily conducted in the State of California, U.S.A. KOEI TECMO administers this Privacy Policy under applicable U.S. and California laws and regulations. If you use our website or service from outside United States, you are thereby consenting for your personal information to be transferred to, stored in and be processed in the United States, the United Kingdom, and/or in other countries by KOEI TECMO and/or its affiliates in the manner described in this Privacy Policy. Your consent to this Privacy Policy followed by your submission of your personal information represents your agreement to such transfer, storage and processing of your personal information. Furthermore, you acknowledge that the privacy laws of the United States and the State of California may differ from the laws in the country where you are located and may not provide you the same rights or protections for your personal information as those laws.

Users in certain jurisdictions may have a right to access his/her personal information held by KOEI TECMO. Your right of access to such personal information can be exercised in accordance with applicable laws, rules and regulations. Please submit any requests for such access to the email address, phone number or postal address set forth in the Contact Us section at the very bottom of this Privacy Policy.

18. Protection of Children’s Privacy

KOEI TECMO is committed to providing special protection for the privacy of children who may use our website. We do not knowingly collect, use or retain personal information from such children. If we discover that we have inadvertently collected personal information from children under the age of 16, we will take all reasonable measures to delete any records of such personal information that come to our attention.

If you become aware that your child has provided us with personal information, please notify us at the contact information set forth in the Contact Us section at the bottom of this Privacy Policy. You may review or request to have deleted any information your child has submitted to us. You may also request that we not collect any personal information about your child in the future.

We also urge parents to instruct their children never to give out their real names, addresses or phone numbers without parental permission when using the Internet. We appreciate your cooperation in assisting us to provide a safe and enjoyable online experience for your children.

19. Changes to this Privacy Policy

We may modify, alter, or update this Privacy Policy at any time, so we encourage you to review this policy frequently. We will not provide individual notice to you of changes to this Privacy Policy, but when we make updates to the policy we will update the date set forth at the top of this Privacy Policy. Your continued use of this website after we post any such changes will constitute your acknowledgment of the modified Policy and your agreement to abide and be bound by the modified Policy.

20. Contact Us

Feel free to email us at Privacy@koeitecmoamerica.com or write us at KOEI TECMO AMERICA Corporation, 831 Mitten Road, Suite 216, Burlingame, CA 94010. Mark envelopes ATTN: Online Privacy.

You can also call us at (650) 692-9080 between the hours of 9:30am and 5:00pm Pacific Time. Ask to speak with a Customer Service Representative and please state the nature of the call.

Please check this Policy each time you use our web site to ensure you are aware of any changes in our privacy practices. Our privacy policy will indicate at the top of the policy the date it was last updated.