SEGA SAMMY CREATION

1.Compliance with Laws and Regulations

The Company will comply with relevant laws and regulations regard to the handling of the information.

2.Acquiring Information

The Company will acquire information by lawful and fair means.

3.Managing Information

The Company will manage information in a manner that maintains the confidentiality, completeness, and availability thereof.

To prevent information loss, destruction, falsification or leakage, the Company will take appropriate information management measures, including restricting and controlling access to the information, establishing controls on entry/exit at departments/divisions handling the information, implementing measures to prevent unauthorized access or system compromise due to computer viruses and the like.

When outsourcing the handling of the information to third parties, the Company will proceed accordingly established procedures to maintain confidentiality.

4.Organization and System

The Company will appoint a person in charge of information management promotion and implement appropriate management of the information. For its employees (including all officers, regular employees, contract employees, dispatched employees, part-time employees, and the like; this definition applying hereafter), the Company will provide education and training on safeguarding and managing the information appropriately to ensure the appropriate handling of the information in day to day business operations.

5.Establishing, Implementing, Maintaining, and Improving the Information Management Program

To enforce this Policy, the Company has established an information management program (including this Policy, “Information Management Rules” and other rules and regulations) and will take all due steps to ensure that such information management program will be thoroughly communicated to the Company’s employees and other related parties and will be implemented, maintained, and improved on a continuing basis.

6.Handling of Personal Information

In light of the importance of safeguarding Personal Information, the Company will comply with all applicable laws and regulations and the provisions of “Handling of Personal Information” to be specified separately, and handle the Personal Information to be collected in an appropriate manner.

1.Compliance with Laws and Regulations

In light of the importance of safeguarding Personal Information, the Company will comply with the Act on the Protection of Personal Information and other relevant laws and regulations.

2.Collection and Use of Personal Information

For the purposes listed in Article 3 below, the Company may collect and/or use the following personal information (the “Personal Information”):

• ・Names, addresses, gender, birth dates, company or organization names, titles, phone numbers, e-mail addresses, information regarding device identifiers, location data and communication records with regard to the Company’s customers and/or business partners;
• ・Names, addresses, gender, birth dates, academic records, career records, phone numbers, e-mail addresses and information regarding relatives with regard to the Company’s job applicants;
• ・Any other personal information necessary for the Company’s proper and efficient operations.

The Company will handle the Personal Information that we manage or in our possession in an appropriate manner and in accordance with the following provisions and make every effort to maintain the Personal Information.

3.Purposes of Use of Personal Information

3-1 The Company will use collected Personal Information to the extent necessary to attain the following purposes only and will not do so for other purposes.

1) Customer Information

• ・Responding to customer inquiries or requests
• ・Providing customers with any information on the Company’s events, campaigns, questionnaires and the like
• ・Distributing e-mail newsletters
• ・Contributing to the planning and development of the Company’s goods, services and the like
• ・Marketing activities

2) Business partner information

• ・Various communications, orders accepted and placed, invoices and payments, and other matters related to transactions
• ・Providing business partners with any information on the Company’s goods, events, campaigns, questionnaires and the like
• ・Contributing to the planning and development of the Company’s goods, services and the like
• ・Marketing activities

3) Information on job applicants for recruiting new graduates and mid-career workers

• ・Contacting job applicants concerning recruitment/employment and management of recruitment/employment

4) Employee information

• ・Management of employees’ personnel/labor/salaries matters
• ・Management of employee duties and security management

3-2 The Company will use the Personal Information including the individual numbers (the “Individual Numbers”) as stipulated in the Act on the Use of Numbers to Identify a Specific Individual in the Administrative Procedure (“My Number Law”) to the extent necessary for the Company to administrate the following matters:

1) Matters related to the Individual Numbers of the Company’s employees (including dependent family members and/or past employees) as follows:

• ・Withholding tax
• ・Payment of salaries and the like
• ・Personal resident tax
• ・Health insurance
• ・Employees’ pension
• ・National pension
• ・Company pension
• ・Unemployment insurance
• ・Industrial accident compensation insurance
• ・Employee stock ownership plan

2) Matters related to the Individual Numbers of persons other than the Company’s employees as follows:

• ・Payment records of compensations, fees and the like
• ・Payment records of rents and the like for real estate
• ・Payment records of consideration for sales of real estate and the like

3) Any other matters related to the above.

4.Management of Personal Information

Safety management measures for the Personal Information are established in the “Information Management Program”, comprised of the Information Security and Privacy Policy, rules based thereon and various other rules and regulations.
The Company will delete the Personal Information when the Company deems it unnecessary to keep such Personal Information continuously due to the attainment of the purpose of the use thereof.

5.Sharing Personal Information with Third Parties

The Company will not share the Personal Information of the person to any third party except in the following cases where:

• 1) Prior consent is obtained from the person;
• 2) The handling of the Personal Information is based on laws and regulations;
• 3) The handling of the Personal Information is necessary for the protection of the life, body, or property of an individual and in which it is difficult to obtain the consent of the person
• 4) The handling of the Personal Information is specially necessary for improving public health or promoting the sound growth of children and in which it is difficult to obtain the consent of the person;
• 5) The handling of the Personal Information is necessary for cooperating with a state organ, a local government, or an individual or a business operator entrusted by either of the former two in executing the affairs prescribed by laws and regulations and in which obtaining the consent of the person is likely to impede the execution of the affairs concerned; and
• 6) Such sharing is otherwise acceptable in accordance with the Act on the Protection of Personal Information.

6.Joint Use of Personal Information

SEGA SAMMY HOLDINGS INC. as well as its subsidiaries and affiliates, including the Company (the “Sega Sammy Group”), will jointly use the Personal Information of customers and business partners as follows:

(1)Personal Information to be jointly used

Names, addresses, gender, birth dates, company or organization names, titles, phone numbers, e-mail addresses, information regarding device identifiers, location data, communication records and information necessary for the Company’s proper and efficient operations.

(2)Scope of the joint users:

Any company within the Sega Sammy Group
For more information regarding the Sega Sammy Group, please see the Sega Sammy Group list.

(3)Purpose of use of the companies in the Sega Sammy Group

• 1) Providing you with any information with respect to such company’s goods, events, campaigns, questionnaires and the like;
• 2) Planning and development of such company’s goods and services and the like;
• 3) Marketing activities;
• 4) Management of records regarding the use or exploitation by customers of such company’s goods and services as well as related records;
• 5) Contacting job applicants, determination on their employment and management of job applicants’ information;
• 6) Conducting background checks on the Sega Sammy Group’s existing or potential business partners whether such business partners or related entities/individuals belong to and/or are associated with an organized crime group (or its members or entities/individuals affiliated therewith) in order to determine whether to start, continuously engage in or otherwise conduct any business transactions with such business partners; and
• 7) Any other matters necessary for such company’s proper and efficient operations.

(4)Contact information with respect to the management of the Personal Information

Sega Sammy Holdings Inc.
Personal Information Inquiry
Sumitomo Fudosan Osaki Garden Tower
1-1-1 Nishi-Shinagawa, Shinagawa-ku,
Tokyo 141-0033 Japan

7.Request for Disclosure and Correction of Personal Information

With regard to the Personal Information in the Company’s possession, the Company will receive requests for disclosure, correction and/or other requests from the owner of such Personal Information under the Act on the Protection of Personal Information.

8.Inquiries regarding Personal Information

If you would like to make an inquiry or request with regard to the handling of your Personal Information as well as the procedures for requests and fees associated therewith, please use an Inquiry Form. Regarding the handling of Personal Information for services provided by any other company of the Sega Sammy Group, please contact the Personal Information inquiry helpdesk of such company.

This Policy is an English translation of the original Japanese Policy (the “Original Japanese Policy”). If one or more of the provisions of this Policy are inconsistent with the provision(s) of the Original Japanese Policy, the Original Japanese Policy shall prevail.