Privacy Notice

Last Updated:  Friday 6 September 2019 12:00
Table of Contents
  • INTRODUCTION
  • HOW & WHEN WE COLLECT YOUR PERSONAL DATA
  • TYPES OF PERSONAL DATA WE COLLECT
  • WHY & HOW WE USE YOUR PERSONAL DATA
  • WHAT THE DIFFERENT LAWFUL BASES MEAN
  • KEEPING YOUR PERSONAL DATA SECURE
  • WHO WE SHARE PERSONAL DATA WITH
  • COOKIES
  • WHERE YOUR PERSONAL DATA IS PROCESSED
  • HOW LONG WE HOLD YOUR DATA FOR
  • YOUR RIGHTS OVER YOUR PERSONAL DATA
  • DATA PROTECTION OFFICER
  • CHANGES AND UPDATES TO THIS PRIVACY NOTICE
  • ANY QUESTIONS?

Privacy Notice

Last Updated:  Friday 6 September 2019 12:00

INTRODUCTION

Hi. We’re Square Enix Limited. You probably know us from all the SQUARE ENIX®, EIDOS®, Crystal Dynamics® and TAITO® branded entertainment content we develop, publish, distribute and license, including: FINAL FANTASY®, DRAGON QUEST®, TOMB RAIDER® and SPACE INVADERS®.

Please take the time to read this Privacy Notice, as it explains how we collect, use and protect your personal data.

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HOW & WHEN WE COLLECT YOUR PERSONAL DATA

From the moment you begin interacting with Square Enix Limited, we are collecting personal data. Sometimes the personal data we collect is provided by you and sometimes it is collected automatically.

You give us data when you: register or update a Square Enix Members account or Square Enix Account, use our paid-for services, play one of our games, enter one of our tournaments, apply for a job with us, attend an interview or assessment, opt-in to receive our marketing messages, subscribe to our mailing lists, call us, email us, live chat with us online, chat to us in-game, make a purchase from us, enter one of our competitions or answer one of our surveys, fill in a form, conduct a search or post content on our website, interact with other users on our online services, register to attend our events, ‘follow’, ‘like’, post to or interact with our social media accounts or apply to be a Square Enix “influencer” on our website.

We collect your data automatically when you: access our website pages, interact with other users on our online services, open an email from us, login to your Square Enix Members or Square Enix Account, play our games online, live chat with us, message us or other users in-game or make a purchase from us.

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TYPES OF PERSONAL DATA WE COLLECT

Depending on the specific services you use and how you interact with us, we may collect various types of personal data as further described in this section.

Contact details

Your name, address, telephone number and email address.

Account profile data

Your name, email address, birth date, username and password.

Financial information

Your bank account number, credit/debit card details and billing address.

Information that identifies you

Your birth date, IP address, login information, browser type and version, time zone setting, browser plug-in types, geolocation information, operating system and version, cookies, Google AdID, Apple IDFA and unique device IDs.

Information on how you use our websites

Your URL clickstreams (the path you take through our site), products/services you view or purchase, page response times, download errors, how long you stay on our pages, what you do on those pages and other actions.

Information on how you purchase and use our games and services

Your gaming platform, game version, mobile and hardware identifiers, device event information, crash reports, language or subtitle options, game scores, game metrics, achievements, rankings, play time, feature usage, player performance and progression, purchases, time zone, timestamp, session duration, challenges or gifts sent to other players and number of friends on the platform.

Survey information

Any information that you decide to provide to us when you complete one of our surveys.

Employment information (only when you apply for job roles with us)

Name, email address, employment history, references, education history, results of pre-employment screening and background checks, relevant experience, achievements, skills and qualifications and the outcome of any interviews or tests that are part of the recruitment process.

Information recorded at Live Square Enix Events

Photographs and videos of you.

Information provided to us by third parties

Game Platforms

Nickname, username, user ID, friends list, email address, geolocation, language and date of birth.

Mobile Platform Providers and App Stores

Username, device ID, purchase history and geo-location.

When you log in with your Facebook account

Account ID, email address and friends playing the same game.

When you log in with your Steam account

Account ID, nickname and email address.

What about sensitive data?

We do not actively collect any “special categories of data” about you (data that is intended to identify your racial or ethnic origin, political opinions, religious/philosophical beliefs or trade union membership, genetic data, biometric data, health data, or data about your sexual life or orientation, criminal offences or alleged offences). Please don’t send us your sensitive data or post it anywhere on our services.

What about children’s data?

You must be at least 13 years old to use any of our services or games, as we do not target our games to children under 13 and do not knowingly collect any personal data from any person under 13.

If you think we have unintentionally collected personal data from someone under the age of 13, please let us know by contacting us here.

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WHY & HOW WE USE YOUR PERSONAL DATA

We will only use your personal data for certain specified reasons and only where we have a lawful basis to do so. Which of the following reasons being applicable to you, depends on the type of relationship we have and how we interact with you. For example, we will not use your personal data for the purpose of processing payments, unless you’ve made a purchase from us.

Registering your account

When you sign up to use our services or register an account with us, we will use the details you provide on your account registration form to process your registration and provide the services you’ve agreed to receive.

Our lawful basis for this use of your personal data is: performing our contract with you.

Keeping our websites and gaming services running

Providing you our games and services online, login authentication, age verification, remembering your settings, processing payments, hosting and back-end infrastructure and access to our websites.

Our lawful bases for this use of your personal data are: performing our contract with you, to comply with our legal obligations and legitimate interests to keep our services running.

Enabling you to communicate with other users

Certain parts of our websites and online services enable you to communicate and interact with other users. We will use information you have provided us to enable these interactions and communications on our websites and online services.

Our lawful basis for this use of your personal data is: performing our contract with you.

Processing payments

We will use your information to process payments for our goods and services.

Our lawful basis for this use of your personal data is: performing our contract with you.

Targeted advertising

Through cookies, clear GIFs, web beacons and tracking pixels we will use your information to deliver relevant advertisements and offers to you and measure the effectiveness of the advertising and offers. These technologies connect your behaviour across different websites, mobile apps and devices and enable tailored advertising to be served to your game, web browser, or mobile device. Please also see our Cookie Notice.

Our lawful basis for this use of your personal data is: your consent.

Social media

We will use your information to communicate with you where you message us, respond to our posts, “like” our posts, tweet or retweet us or otherwise interact with us directly on social media platforms.

Our lawful basis for this use of your personal data is: our legitimate interests in promoting our brand and communicating with interested individuals.

Anti-cheat, anti-tampering, fraud and unlawful activity detection, prevention and investigation

To enforce our rules and policies, protect our customers and business, maintain the competitive integrity of our games, and investigate and respond to fraudulent, unauthorised or illegal activity on our services.

Our lawful bases for this use of your personal data are: our legitimate interests to operate a safe and lawful business or where we have a legal obligation to do so.

Square Enix “Press Centre” registration

When you register your details to join the Square Enix Press Centre, we will use the information you provide to process your application and, in some cases, to send you press releases and assets as part of the Press Centre program.

Our lawful basis for this use of your personal data is: our legitimate interests to recruit the most suitable influencers for our campaigns.

Square Enix “influencer” registration and suitability monitoring

When you apply to become a Square Enix influencer through the Square Enix partner program, we will use the information you provide to process your application and, in some cases, to contact you about your potential participation in the program.

Our lawful basis for this use of your personal data is: our legitimate interests to recruit the most suitable influencers for our campaigns.

Community and customer support

Handling all enquiries or complaints, troubleshooting and solving technical issues over live chat, phone, email and in-game chat, making necessary changes to our products and services and monitoring your participation in our forums and all parts of our services that allow you to publicly post information or interact with other users.

Our lawful bases for this use of your personal data are: performing our contract with you, our legitimate interests to provide you with customer service, our legitimate interests in providing the correct products and services to our website users or to comply with our legal obligations.

Improving and developing our games, services and websites

Traffic optimisation, in-game data collection, analytics and research, including profiling and the use of machine learning (we sometimes use carefully selected third parties to do this on our behalf), cheat detection and prevention, managing landing pages and heat mapping our sites.

Our lawful bases for this use of your personal data are: performing our contract with you and our legitimate interests in learning about the types of people who are interested in our games, websites and services, to keep our games, online services and websites updated and relevant, to develop our business and to inform our marketing strategy.

Recruitment

To evaluate your suitability for a role that you have applied for, verify your application details, academic qualifications and work experience, perform background checks, review and audit our recruitment processes and its outcomes and identify any future employment opportunities that you may be suitable for.

Our lawful basis for this use of your personal data is: our legitimate interests to recruit new employees or contractors.

Contests and Tournaments

To process your entry into contests, tournaments, surveys or other promotional events that we run from time to time, should you decide to participate in them. In some cases our tournaments may have a “leaderboard” element, in which case we may display your name on a publicly accessible leaderboard.

Our lawful bases for this use of your personal data are: your consent or contract.

Live Square Enix Events

To photograph you and record videos which you may be visible in.

Our lawful bases for this use of your personal data are: our legitimate interests if you are a guest at the event or contract if you are a contestant.

Marketing

Sending you communications about our services, products and features that you have agreed to receive.

Our lawful bases for this use of your personal data are: your consent or our legitimate interests to provide you with marketing communications where we may lawfully do so.

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WHAT THE DIFFERENT LAWFUL BASES MEAN

This section explains what the lawful bases we rely on for processing your personal data actually mean.

Consent

You have provided us clear and unambiguous consent for us to process your personal data for a specific purpose. You have the right to withdraw this consent at any time.

Contract

We need to process your personal data for us to fulfil our contractual relationship with you.

Legitimate interests

We need to process your personal data for our legitimate interests, or the legitimate interests of a third party, in conducting and managing our business and our relationship with you. Where we use your personal data for our legitimate interests, we try to take into account any potential impact that such use may have on you.

Legal obligation

We have a legal obligation under applicable law to process your personal data.

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KEEPING YOUR PERSONAL DATA SECURE

We treat your personal data with care and take reasonable steps to protect it, including the use of physical, technical and administrative safeguards to protect your personal data from unauthorised access, use or disclosure.

For this reason, we secure access to all transactional areas of our websites and apps, restrict access to your personal data, secure and tokenise transactional information and regularly monitor our systems for possible vulnerabilities and attacks.

If you believe your personal data has been breached, please contact us immediately at DPO@eu.square-enix.com.

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WHO WE SHARE PERSONAL DATA WITH

Depending on the purpose for which we collect your personal data or the nature of our interaction with you, we may use third parties to process some of your personal data (for example, we engage third parties to process information about your purchases and use of our games). We require that these third parties use only the information they need to perform their specific services as specified in our contract with them. If we stop using any such third party’s services, we require that your personal data held by them is either securely and permanently deleted or rendered irreversibly anonymous. In all cases, we apply measures to keep your data safe and your privacy protected.

We share your personal data with third-party IT companies who support our website, online services and other business systems, payment services providers who process your payments for goods and services, fraud detection and prevention companies who help us prevent cheating, abuse, fraud, tampering or other unauthorised use of our services and direct marketing companies who help us manage our electronic communications with you.

We may share your personal data with Google, Facebook and other third-party advertising partners so they can show you products that might be of interest to you while you are browsing the internet or playing our mobile games. For example, if you provide us with your email address we may share it with Facebook so that you can receive targeted ads from us when you use Facebook, and so that other users of Facebook who share similar interests to you can also receive targeted ads from us. This is based on your consent to marketing.

Under very specific circumstances, we will share your personal data with third parties (including law enforcement bodies) in order to respond to fraudulent or criminal (or potentially fraudulent or criminal) activity on our systems or at our events. We may also be required by law to disclose your personal data to the police or to another law enforcement, regulatory or government body in your country of origin or elsewhere, including upon receiving a legally valid request to do so.

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COOKIES

Cookies are small amounts of information in the form of text files which are stored on the device you use to access our website. We use cookies to allow our services to operate effectively and to enhance your experience when using our services and to bring you relevant advertising.

Please have a look at our Cookie Notice for more information.

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WHERE YOUR PERSONAL DATA IS PROCESSED

We are a global organisation, so we sometimes need to share your personal data with our other offices, or with other third parties and suppliers, who are located outside the European Economic Area (“EEA”).

When it is necessary for us to transfer your personal data out of the EEA, we will only do so where the transfer is authorised under applicable EU law, including where the transfer is made to a country the European Commission has deemed to have adequate data protection laws, is governed by the Model Contractual Clauses (European Commission: Model contracts for the transfer of personal data to third countries) for data transfers between EU and non-EU countries or is authorised by another recognised transfer mechanism under applicable law. For transfers to our offices in the U.S., we do so under the E.U.-U.S. and Swiss-U.S. Privacy Shield Framework, which we participate in. This is to ensure that suitable safeguards to protect the privacy and security of your personal data are applied and are consistent with your relationship with us and the practices described in this Privacy Notice. To learn more about the Privacy Shield Framework, please visit European Commission: EU-US Privacy Shield. To view our certification under the Privacy Shield Framework, please visit https://www.privacyshield.gov/list.

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HOW LONG WE HOLD YOUR DATA FOR

We will only retain your personal data for as long as you are a customer or are using our services and for no longer than is necessary after that. We will securely destroy or irreversibly anonymise your personal data once it is no longer necessary for us to retain it.

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YOUR RIGHTS OVER YOUR PERSONAL DATA

This section describes the various rights you have over your personal data under the General Data Protection Regulation (Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016), how you can invoke these rights with us and where you can find more detailed information about these rights.

Your right of access

You have the right to request copies of your personal data. This right always applies. However, there are some exemptions, which means you may not always receive all the personal data you request. More about this right.

Your right to rectification

You have the right to request that we rectify information you think is inaccurate or complete information you think is incomplete. This right always applies. More about this right.

Your right to erasure

You have the right to request that we erase your personal data in certain circumstances. More about this right.

Your right to restriction of processing

You have the right to request that we restrict the processing of your personal data in certain circumstances. More about this right.

Your right to object to processing

You have the right to object to us processing your personal data under certain circumstances, including where we do so based on our legitimate interests. More about this right.

Your right to data portability

You have the right to request that we transfer your personal data to another organisation, or that we provide a copy of it to you. This right only applies to personal data you have given us and that we are processing based on your consent or our contract with you. More about this right.

You are not required to pay any charge for exercising these rights.

For more information or to exercise your above rights, please email us at DSAR@eu.square-enix.com or write to us at:

FAO: Data Protection Officer

Square Enix Ltd

240 Blackfriars Road

London, UK

SE1 8NW

You may also lodge a complaint regarding our use of your personal data. If you have such a complaint, we ask that you please tell us first so we can have a chance to look into your concerns. If you remain unsatisfied, you can contact the Information Commissioner’s Office on their website at www.ico.org.uk/make-a-complaint.

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DATA PROTECTION OFFICER

Square Enix Limited is headquartered in London, in the United Kingdom. We have appointed a data protection officer for you to contact if you have any questions or concerns about your personal data. Our data protection officer can be contacted at:

DPO@eu.square-enix.com, or by writing to:

FAO: Data Protection Officer

Square Enix Ltd

240 Blackfriars Road

London, UK

SE1 8NW

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CHANGES AND UPDATES TO THIS PRIVACY NOTICE

As our services and products change from time to time, you should expect this Privacy Notice to change as well. We reserve the right to amend this Privacy Notice at any time, for any reason. We will make all reasonable endeavours to notify you of any changes. We may also email periodic reminders of this Privacy Notice, and will email customers who have a registered Square Enix Account or Square Enix Members account of any material changes to this Privacy Notice. Nevertheless, you should check here regularly to see the current Privacy Notice that is in effect and any changes that may have been made to it.

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ANY QUESTIONS?

You made it to the end! We do hope you have enjoyed reading this Privacy Notice and we commend you on your dedication to understanding how we handle your personal data and your rights to control it. If this Privacy Notice hasn’t answered all your questions, or if you have any comments or ideas about how we can make this Privacy Notice even better, please don’t hesitate to contact our DPO at the below:

DPO@eu.square-enix.com

or in writing to:

FAO: Data Protection Officer

Square Enix Ltd

240 Blackfriars Road

London, UK

SE1 8NW

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