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SEGA OF AMERICA, INC. PRIVACY POLICY 3

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2. OUR USE OF COLLECTED INFORMATION

We may use your information in the following ways:

(A) REGISTRATION INFORMATION:

(i)  to create your profile and so you can access our Products;

(ii)  to identify you when you sign in;

(iii)  to give you access to your communications and privacy preferences;

(iv) to contact you for your views on our Products;

(v)  to notify you of changes or updates to our Products; and

(vi)  for marketing purposes, based on your communication and privacy preferences.

(B) BILLING INFORMATION:

(i)  to verify your purchase of our Products and process any refunds;

(ii)  to reply to any queries and questions and to resolve problems;

(iii)  to carry out analysis and research to develop our Products; and

(iv)  to protect you and our Products by seeking to detect and prevent fraud or other acts in breach of our user agreements or policies relevant to our Products.

(C) TECHNICAL AND DEVICE INFORMATION:

(i)  to provide you with an optimal experience;

(ii)  to understand how you interact with our Products

(iii)  to provide Products you request; 

(iv)  to measure and analyze the use and effectiveness of our Products;

(v)  to understand which of your devices are using our Products and playing our videogames;

(vi)  to provide safe and fair gaming environments;

(vii)  to customize and optimize the targeting of our advertising both within our Products and across our websites;

(viii)  to operate and improve our Products; and

(ix)  to fix errors.

(D) FEEDBACK / SURVEYS / USER RESEARCH:

(i)  to reply to your questions or queries;

(ii)  to record comments and information which you provide on our gaming forums; and

(iii)  to conduct analysis and research to improve and develop our Products.

(E) INFORMATION FROM PUBLICLY AVAILABLE ONLINE SOURCES:

(i)  to understand the community sentiment about our Products.

(F) INFORMATION ABOUT YOUR USE OF OUR PRODUCTS:

(i)  to track the performance of our Products;

(ii)  to communicate with Platform Operators and our other partners; and

(iii)  to improve our advertising and targeting systems.

(G) INFORMATION ABOUT YOUR PARTICIPATION IN SWEEPSTAKES: 

(i)  to verify your identity;

(ii)  to distribute prizes to you; and

(iii)  to carry out publicity activities relating to the sweepstake. 

(H) INFORMATION FROM ANTI-CHEAT AND ANTI-HACKING TECHNOLOGIES:

(i)  to detect illegal or malicious activity in our Products.

(I) INFORMATION FROM LIVEOPS SOFTWARE: 

(i)  to provide certain in-game features and functionality.

(J) EVENTS AND PROGRAMS

(i)  to operate events and programs; and

(ii)  to communicate with you about events, programs, and our Products.

We may combine the information we collect through our Products with information we collect automatically or receive from other sources identified in this Policy and use such combined information in accordance with this Privacy Policy. Your browsing activity may be tracked across different websites and different devices or apps. For example, we may attempt to match your browsing activity on your mobile device with your browsing activity on your laptop. To do this our technology partners may disclose data, such as your browsing patterns, geo-location and device identifiers, and will match the information of the browser and devices that appear to be used by the same person.

We may also aggregate and/or de-identify information collected through our Products in such a way that the information cannot reasonably be linked to you or your device. We may use de-identified or aggregated data for any purpose, including for research and marketing purposes, and we may disclose such data to any third parties, including advertisers, promotional partners, sponsors, and others.

Below is a more detailed explanation of purposes for which we use the personal information we collect:

(A) REGISTRATION INFORMATION

Your registration information enables us to create your profile, provide you with access to our Products and to give you access to your user preferences. This is necessary for the purpose of performing the contract we have with you. It helps us to authenticate your access, to contact you for your views and to notify you of important changes or updates to our Products.   

If you choose to sign up for our Products using third party services such as your Facebook account, that provider may provide your personal information with us subject to their privacy policy and the privacy settings of your account with them.  This may also enable the provider and us to link your activities with your personal registration information at their site, and may include notifying your friends about your activities while using our Products. If you sign up via third party services you should visit the third party website and review their privacy policy and your registration profile or account to understand how your data is processed by them and to find out what your options are. 

When we have your consent and in accordance with your stated communication preferences, we may also contact you for marketing purposes to let you know by email, telephone, mobile or in-app messaging about our other products and services. We provide further information below in the "Marketing Communications” portion of Section 6.

(B) BILLING INFORMATION

This information will enable us to facilitate and verify your purchases, including with third party stores and Platform Operators, and to contact you  to assist with resolving any problems with your purchases and to process any refund payments that you may be due.  

We will also use and analyze information on transactions on your account by data matching or statistical analysis so that we can administer, support, improve and develop our business and to help us detect and prevent fraud, or other illegal activities, or acts prohibited by our terms of service or any policies applicable to our Products.  

(C) TECHNICAL AND DEVICE INFORMATION

We use internet log files to monitor traffic on our Products, resolve technical problems and to detect and prevent fraud.   

We use technical and device information to provide us with information, such as when an email is opened, or to develop statistics on the effectiveness of advertising or marketing on our websites. In some cases, working with third-party partners, we use this information to send you ads for our Products based on your interests. 

We also use technical and device information to operate and improve our Products, enable online matchmaking, facilitate sharing, measure our effectiveness, set up and maintain accounts, identify and fix errors and to help keep online content fair and safe and to resolve related disputes.  

(D) FEEDBACK / SURVEYS / USER RESEARCH

We use your feedback to reply to your questions or queries, to provide customer support and resolve problems relating to any of our Products. We will also publish reviews about our Products that you submit to us for this purpose and will conduct analysis of feedback for the purpose of improving and developing our Products.  SEGA may also film and record user research sessions with your permission so that we can observe your playing habits and record your feedback. 

SEGA uses the information collected during surveys and user research sessions to help us to tailor and improve our Products. 

SEGA may share data from user research sessions with certain third-party partners when there is a legitimate business operation interest to do so. In such circumstances, your data will always be fully anonymized before it is shared. 

(E) INFORMATION FROM PUBLICLY AVAILABLE ONLINE SOURCES

We will use and analyze this data to learn about how you use our Products, how you engage with our marketing campaigns and to gain an understanding of community sentiment about our Products.  We may use third party analytics providers who collect this data on our behalf. 

(F) INFORMATION ABOUT YOUR USE OF OUR PRODUCTS 

This information enables us to track the performance of our Products, develop new Products, optimize your experience, and communicate with Platform Operators and our other partners. It also enables us to better understand our users and improve our advertising, targeting and measurement systems.  

We analyze information about how you engage with our Products to understand how our Products are used and to provide you with an optimal gaming experience, such as by rolling out performance-optimising software updates for our Products.  We use this data in order to analyze and produce statistics relating to the habits, usage patterns and demographics of users as a group or as individuals.  This allows us to deliver you customized content, helps us understand the features of our Products that appeal to you and allows us to manage advertising, amongst other things. 

We may also provide functionality within our Products which enables you to upload gameplay footage to YouTube. If you choose to use this feature, we will receive and store an authentication token from Google so that the feature will operate properly.  The use of this functionality is governed by YouTube’s Terms of Service: https://www.youtube.com/static?template=terms.  Further information about the protection of your privacy can be found in Google’s privacy policy: https://policies.google.com/privacy?hl=en-US. You can also view and modify your permissions via Google’s security settings: https://myaccount.google.com/permissions. 

(G) INFORMATION ABOUT YOUR PARTICIPATION IN SWEEPSTAKES 

SEGA collects and processes this data for the purposes of running and monitoring a sweepstake, as well as for carrying out publicity activities relating to the sweepstake.

(H) INFORMATION FROM ANTI-CHEAT AND ANTI-HACKING TECHNOLOGIES 

SEGA may utilize anti-cheat and/or anti-hacking technologies to help us detect an illegal or malicious activity and to take the appropriate actions if such activity is detected. 

The anti-cheat/hacking technologies within your Product may require you to download certain data to your device. If you disable or otherwise tamper with these technologies, the Product may not operate properly and you will be in breach of the applicable end user license agreement. 

(I) INFORMATION FROM LIVEOPS SOFTWARE 

Our Products may include third party LiveOps software which helps us to provide in-game features that are core to your gameplay experience. For example, the software may enable us to offer multiplayer modes, leader boards, in-game rewards and more.

(J) EVENTS AND PROGRAMS

We use information collected from and about you in relation to events and program in order to operate those events and programs and communicate with you about them and our Products.

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