Koei Tecmo Games Co., Ltd. ("Koei Tecmo" or "we" or "our" or "us") take your privacy very seriously and are committed to process your personal data in transparent, fair, and secure ways. As you use our game titled "Three Kingdoms HEROES" for Apple Arcade ("the Services"), we collect, use and share with third-parties certain personal data about you.
This Privacy Policy is intended to provide you with information on how, why and on what ground we collect, use, and share your personal data and the legal rights you can exercise on your personal data. By using our Services, you consent to this Privacy Policy and our collection, using and sharing your personal data, and other activities as described. If you do not agree to this Privacy Policy, please uninstall, and discontinue use of the Services.
The following country-specific exhibit may also apply to you depending on the area in which you reside or are located, so please refer to the country-specific exhibit. If this main text of the Privacy Policy conflicts with the exhibit, then the exhibit will prevail to the extent that such conflict exists.
- Exhibit: EEA (European Economic Area) and the UK
- Exhibit: U.S.
Please note that "personal data" in 2, 3, and 10 below shall include "personal information" under the meaning of Act on Protection of Personal Information of Japan.
We may modify, add to, or delete part of this policy from time to time. We will notify you of any such update by the method of email, posting on the official website, or notice inside the Services.
This Privacy Policy is issued on behalf of KOEI TECMO GAMES CO., LTD., which is the controller within the meaning of the GDPR and is responsible for collecting and using your personal data in the context of providing the Services.
For the purpose described in Section 3 above, we may transfer personal data to foreign countries and regions outside of your residence including Japan, and we will take appropriate protection measures to transfer personal data.
Our Services are not marketed to, or intended for those who under the age of 13 years old. We may collect age information before allowing a user to proceed for certain services and if we discover that we have inadvertently collected personal data from children under the age of 13, we will take all reasonable measures to delete any records of such personal data that come to our attention.
You can lodge complaints if you are not satisfied with our way of processing your personal data with data protection supervisory authority.
For further information and inquiry, contact:
Privacy Policy Contact
KOEI TECMO HOLDINGS CO., LTD.
1-18-12 Minowa-cho, Kouhoku-ku,
Yokohama, 223-8503, Japan
E-mail: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.