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SQUARE ENIX, INC.
PRIVACY POLICY

Revised: October 30, 2017


OVERVIEW

This Square Enix, Inc. Privacy Policy (“SEA Privacy Policy”) explains how your information is collected, used, and shared. Here is a quick summary of key points:

· We ask you for, and use technology to detect, information about you. Some of this information is shared with others, including advertisers. In addition, third parties, including advertisers and advertising services providers, may collect or be given information about you.

· We use technology to collect in-game behavior to improve game performance and backup in-game purchases should they need to be restored or accessed on another device.

· To provide relevant advertising, possibly including targeted and location-based advertising, we may share, and third parties may collect or share, certain information (such as the location of your device) about you.

· We track media performance, which requires that behavioral data be collected by and/or shared with third parties before and after the application or service is downloaded or used.

· Although we may ask for Personal Information (defined below), we will not share such information with unaffiliated third parties except as disclosed herein, as required by applicable law, or with your consent.

· EU data subjects may opt-out of the processing of their personal data for marketing purposes by following the instructions set out herein.

Click here for an index of topics covered in our SEA Privacy Policy; click on any topic for more details.

Introduction

This SEA Privacy Policy describes how Square Enix, Inc. and its affiliates (collectively “Square Enix,” “Company,” or “ we,” “our” or “us”) collect, use, and share information about you and applies to your use of any applications and services, and all interactive elements accessed through those applications and services, that are owned and/or operated by us and post a link to this SEA Privacy Policy (collectively, the “Services”).

Our SEA Privacy Policy covers only information collected directly by us through the Services, and does not apply to information collected by third parties that may interact with our Services, or to our data collection activities outside of our Services (e.g., through websites that support specific products, which may have different privacy policies).

For your California Privacy Rights and European Privacy Rights click on these links.

Square Enix participates in the E.U.-U.S. and Swiss-U.S. Privacy Shield Framework. To learn more, click here .

In addition, please review the Square Enix, Inc. Terms of Service (“ SEA Terms of Service”), which governs your use of the Services. By using our Services, you consent to our SEA Privacy Policy and SEA Terms of Service and our collection, storage, sharing and use of your information and data, and other activities, as described. If you do not agree to this SEA Privacy Policy, do not access the Services, and in the case of mobile applications, uninstall the mobile applications immediately.

This SEA Privacy Policy and the ESRB certification seals shown on our Services confirm that Square Enix is a valid licensee, and participating member, of the Entertainment Software Rating Board's Privacy Certified Program (“ESRB Privacy Certified”). To protect your privacy, we have voluntarily undertaken this privacy initiative, and all of our Services where this SEA Privacy Policy is posted have been reviewed and certified by ESRB Privacy Certified to meet established online information collection, use and disclosure practices. As a licensee of this privacy program, we are subject to frequent audits of our Services and other enforcement and accountability mechanisms administered independently by ESRB Privacy Certified.

Table of Contents

It is important that you read and understand the entire SEA Privacy Policy before using the Services. However, this table of contents highlights key points. You must click on the headings for a more detailed explanation.

1. What Information Do the Services Collect?

(a) Information You Choose to Provide to Us

You may give us Personal Information and other information when you register or use our Services.

(b) Information Collected as You Access and Use the Services

We may use Tracking Technologies to collect your information. This helps do things like deliver preferred content, track game play advancement, and send you relevant ads.

Third parties may also use Tracking Technologies with our Services to collect information about you, and we are not responsible for the practices of these third parties. By installing and using the Services you consent to encountering first-party and third-party Tracking Technologies.

(c) Information Third Parties Provide about You

In addition to the information we collect from you directly, we may also receive information about you from third parties for various purposes.

(d) Information from Interacting with Third-Party Locations

If you interact with third-party sites (such as using Facebook to log in), those sites may send us information about you or we may send them information about you. You should review the applicable third-party privacy policies before using third-party tools on or in connection with our Services, and we are not responsible for these parties’ practices.

(e) Information You Provide about a Third Party

You may give us information about others, such as when you send a friend a message. We will not use their Personal Information to separately market to them unless they consent.

2. How Do We Use the Information We Collect?

(a) Use of Information by Us

We may use your information for a variety of purposes, including to manage, improve and protect the Services, and to send you promotional and transactional communications.

(b) Square Enix Account

We may update your existing Square Enix account, or create one for you, with information collected via the Services.

3. How and When Do We Disclose Information to Third Parties?

We provide your information to third parties under various circumstances. These include:

(a) When You Agree to Receive Information from Third Parties

(b) Third Parties Providing Services on Our Behalf

(c) Administrative and Legal Reasons

(d) Business Transfer

(e) Co-branded Areas

(f) Your California Privacy Rights

(g) Your European Privacy Rights

4. What about Information I Disclose Publicly?

(a) User Generated Content and Public Information

Posting content in public areas makes it available to us and to others.

(b) Name and Likeness

You grant us the right to use your name, likeness and/or usernames in connection with your posting and activities.

5. Do Third-Party Content and Links to Third Party Services Appear on the Services?

We are not responsible for third-party websites or your interaction with third-party content.

6. What about Third-Party Applications that Appear on the Services?

We are not responsible for your interaction with third-party applications.

7. What about Third-Party Ads and Analytics on the Services?

We and third parties may send you targeted or untargeted ads based on your location and behavior. We do not respond to “Do Not Track” signals we receive.

8. How Do I Change My Information or Request Access to It?

You may access and change certain account information, including Personal Information. You may also request access to the Personal Information we have collected from you, and we will make good faith efforts to accommodate such requests.

9. How Do I Change My Communications Preferences?

You may cancel or modify certain email communications you receive from us by following instructions contained within our promotional emails or, where applicable, logging into an account you have created for our Services and changing your preferences.

10. What about the Transfer of Information to the United States or Other Countries?

We may transfer data internationally, including to our facilities in the United States, Japan, Canada and the European Union. We participate in the E.U.-U.S. Privacy Shield Framework.

11. What Should Parents Know about Children?

All of our Services are targeted towards users 13 years old and up. We do not knowingly collect and store Personal Information from a user(s) under 13 years old (“Child” or collectively “Children”) without verifiable parental consent. If you think we have unintentionally collected Personal Information from a Child, please let us know.

12. What about Security?

No data security is absolute, but we take reasonable and appropriate steps to help secure data.

13. What if I have a Question or Complaint?

Email us at na.privacypolicy@square-enix.com, or send us a letter at:

Square Enix, Inc., Attn: SEA Privacy Policy Administrator, 999 N. Sepulveda Blvd., 3rd Floor, El Segundo, CA 90245.

14. What about Changes to the SEA Privacy Policy?

We may change this SEA Privacy Policy as explained here.



The Full Privacy Policy:

1. What Information Do the Services Collect ?

(a) Information You Choose to Provide to Us

On the Services, you may provide to us personally identifiable information, which is information that can reasonably be used to identify you personally, such as your first and last name, date of birth, email address, and address (“Personal Information”). We may collect Personal Information and other information, including demographic information such as gender, age, marital status, education level and occupation, through various forms and in various places on the Services, including account registration forms and “contact-us” forms.

(b) Information Collected as You Access and Use the Services

We and our third-party service providers may use a variety of technologies that passively collect certain information whenever you use the Services (“ Usage Information”) via a device or browser used to interact with our Services (a “Device”). This Usage Information may include the type of browser and/or platform that you are using, the website or app that referred you to our Services, the areas within our Services that you visit and your activities there, your Device location, your Device characteristics and certain Device data, and the time of day you access our Services, among other information. We may use Usage Information for a variety of purposes, including assessing, enhancing or otherwise improving our Services or our activities in connection with them. In addition, we may collect your IP address or other unique identifiers, or assign one to your Device (each a “Device Identifier”), so that our computers can identify the Device. We may access and use Device Identifiers that have already been associated with your Device, and may modify such identifiers to create a new identifier or associate a wholly new identifier with you or your Device. Usage Information may be non-identifying or may be associated with you. To the extent we combine Usage Information with Personal Information (including a Device Identifier), we will treat such combined data as Personal Information under this SEA Privacy Policy.

Some of our Services may collect and transmit precise, real-time information about the location of your Device. For our mobile applications, you are made aware of this at the time you first open the Services with this functionality. Unless it is needed for operation or monetization of the Services, the Services may give you the option to turn location tracking on or off or otherwise manage location services. You can always terminate our location tracking by uninstalling our mobile applications.

We may use various current – and later – developed technologies to collect information about you (“Tracking Technologies”). A few of the methods that may be used to collect such data include, without limitation, the following:

Cookies: A cookie is a data file placed on a Device when it is used to visit the Services (“Cookies”). Cookies may be used for many purposes described in our Square Enix, Inc. Cookie Policy, including, without limitation, remembering you and your preferences and tracking your visits to and activities on the Services. Some features of the Services may not function properly if you choose to disable Cookies, and some types of Flash and HTML5 Cookies may not be disabled using browsers. In some instances, especially with respect to mobile, we may require you to uninstall / not use the Services rather than have a poor experience from disabling Cookies.

Embedded Scripts: An embedded script is programming code that is designed to collect information about your interactions with the Services, such as the links you click on. The code temporarily downloaded onto your Device from our web server or a third-party service provider is active only while you are connected to the Services, and is deactivated or deleted thereafter.

Web Beacons: Small graphic images or other web programming code called web beacons (also known as “1x1 GIFs” or “clear GIFs”) may be included in our Services’ pages and messages. Web beacons may be invisible to you, but any electronic image or other web programming code inserted into a page or email can act as a web beacon. Web beacons or similar technologies may be used for a number of purposes, including, without limitation, to count visitors to the Services, to monitor how users navigate the Services, to count how many emails that were sent were actually opened, or to count how many particular articles or links were actually viewed.

ETag, or entity tag: A feature of the cache in browsers, an ETag is an opaque identifier assigned by a web server to a specific version of a resource found at a URL. If the resource content at that URL ever changes, a new and different ETag is assigned. Used in this manner, ETags are a form of Device Identifier. ETag tracking may generate unique tracking values even where the consumer blocks HTTP, Flash, and HTML5 cookies.

Third parties may use Tracking Technologies with our Services. We may not control those third-party Tracking Technologies and in such event, we are not responsible for them. However, you consent to potentially encountering third-party Tracking Technologies in connection with the use of our Services, and accept that our representations under this SEA Privacy Policy do not apply to the Tracking Technologies or practices of such third parties . This applies even if they share the collected data with us, except that if we combine that data with Personal Information we have collected on the Services, we will treat it as Personal Information under this SEA Privacy Policy.

For more information on advertising and related Tracking Technologies, click here.

(c) Information Third Parties Provide about You

We may, from time to time, supplement the information we collect directly from you on our Services with outside records from third parties for various purposes, including to enhance our ability to serve you, to tailor content and ads to you, and to offer you opportunities that may be of interest to you. To the extent we combine such information we receive from those sources with your Personal Information we collect on the Services, it will be treated as Personal Information and we will apply this SEA Privacy Policy to such combined information. In no other circumstances do our representations under this SEA Privacy Policy apply to information we receive about you from third parties, even if they have used our technology to collect it and share it with us.

(d) Information from Interacting with Third-Party Locations

The Services may include functionality that allows certain kinds of interactions between the Services and your account on a third-party web site or application. Here are two examples:

(1) Login: We may provide an option to use your Facebook, Google or other account provided by a third-party site or application to facilitate the registration and login or transaction process on the Services. If you choose to use such options to access our Services, the third-party site or application may send Personal Information about you to the Services. If so, we will then treat it as Personal Information under this SEA Privacy Policy.

(2) Social Communication: You can also engage with our content on or through third-party social networking sites, such as Facebook and Twitter (or third-party social media plug-ins and applications). When you engage with our content on or through third-party social networking sites, plug-ins and applications, you may allow us to have access to certain information from your social media profile (e.g., name, email address, photo, gender, birthday, location, your list of friends, people you follow and/or who follow you, the posts or the ‘likes’ you make) to deliver the content or as part of the operation of the application. When you provide information from your social media account, it can help enable us to do things like (1) give you exclusive content, (2) personalize your online experience with us within and outside our Services, and (3) contact you or advertise to you through the social networking sites or directly by sending you the latest news, special offerings, and rewards. By doing so, you consent to the use of the information you provided in accordance with this SEA Privacy Policy. However, please be aware that we may not control or have access to your communications through these third parties, these third parties may retain any information used or provided in any such communications or activities, and these third parties are not subject to this SEA Privacy Policy. You should review the applicable third-party privacy policies before using such third-party tools on our Services, and we are not responsible for these third parties’ practices.

For more information about how social networking sites handle your personal information, please refer to their privacy policies and terms of use.

(e) Information You Provide about a Third Party

You may send someone else a communication from the Services, such as sending an invitation or message to a friend. If so, the information you provide about them (names, email addresses, etc.) is used solely to facilitate the communication and is not used by us for any other marketing purpose unless we obtain consent from that person or we explicitly say otherwise. Please be aware that when you use any “send-to-a-friend” functionality on our Services, your Personal Information may be included in the communication sent to your addressee(s). Some of these tools may be third-party tools subject to third-party privacy policies, as further detailed in Section 1(d) above.

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2. How Do We Use the Information We Collect ?

(a) Use of Information by Us : We may use your Personal Information, Usage Information, or other information that is subject to this SEA Privacy Policy: (1) to provide you or people like you with information or services or process transactions that you have requested or agreed to receive, including electronic newsletters, special offers or promotional materials on behalf of us or third parties; (2) to enable you to participate in a variety of the Services’ features; (3) to process your registration with the Services, including verifying your information is active and valid; (4) to create a Square Enix Account to provide you access to the Square Enix Account Service; (5) to improve the Services, to customize your experience on the Services, or to serve you specific content that is relevant to you, including targeted advertising; (6) to contact you with regard to your use of the Services and, in our discretion, changes to the Services and/or Services’ policies; (7) for internal business purposes; and (8) for purposes otherwise disclosed at the time you provide your information or as otherwise set forth in this SEA Privacy Policy.

(b) Square Enix Account: Upon your installation of the Services and acceptance of this SEA Privacy Policy and the SEA Terms of Service, information collected via the Services may be used to create a new, or update your existing, Square Enix Account, which is also subject to this SEA Privacy Policy.

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3. How and When Do We Disclose Information to Third Parties ?

We may share non-Personal Information, such as aggregated user statistics, with third parties. We may share your Device Identifiers with third parties along with data related to you and your activities. We and/or third parties may collect, and share with others, your Device Identifiers and Usage Information in connection with advertising as more fully explained in Section 7. In addition, we may share the information we have collected about you, including Personal Information, as disclosed at the time you provide your information, with your consent, or as described in this SEA Privacy Policy.

(a) When You Agree To Receive Information from Third Parties: You may be presented with an option on our Services to receive certain information and/or marketing offers directly from third parties. If you choose to do so, your Personal Information will be disclosed to such third parties and all information you disclose will be subject to the third-party privacy policies and practices of such third parties. We are not responsible for such third-party privacy policies and practices of such third parties and, therefore, you should review such third-party privacy policies and practices of such third parties prior to agreeing to receive such information from them. If you later decide that you no longer want to receive communications from one of these third parties, you will need to contact that third party directly.

(b) Third Parties Providing Services on Our Behalf: We may use third-party agents, vendors, consultants, and other service providers to perform certain services on behalf of us or the Services, such as hosting the Services; developing, designing and/or operating the Services’ features; tracking the Services’ activities and analytics; performing surveys or other user research; and enabling us to send you or people like you special offers or perform other administrative services. These third parties may be granted access to your information, including Device Identifiers and Personal Information, to carry out the services they are performing for you or for us.

Third-party analytics, user research, and similar service providers may set and access their own Tracking Technologies on your Device and they may otherwise collect or have access to information about you, potentially including Personal Information.

(c) Administrative and Legal Reasons: We may access, use, preserve, transfer and disclose your information to third parties: (i) in response to lawful requests by public authorities, including to meet national security or law enforcement requirements; (ii) to satisfy any applicable law, regulation, subpoena, or governmental requestor legal process, or any legal process in connection with a court proceeding or arbitration, if in our good faith opinion such is required or permitted by law; (iii) to protect and/or defend the Services’ SEA Terms of Service or other policies applicable to the Services, including investigation of potential violations thereof; (iv) to protect the safety, rights, property or security of the Services, our staff, or any third party; and/or (v) to detect, prevent or otherwise address fraud, security or technical issues. Further, we may use IP addresses or other Device Identifiers to identify users, and may do so in cooperation with third parties such as copyright and trademark owners, internet service providers, wireless service providers and/or law enforcement agencies, including disclosing such information to such third parties, all in our discretion, subject to applicable law. Such disclosures may be carried out without notice to you.

(d) Business Transfer: We may share your information with our parent, subsidiaries and affiliates within and outside of the United States. We also reserve the right to disclose and transfer all such information: (i) to a subsequent owner, co-owner or operator of the Services or applicable database; or (ii) in connection with a merger, consolidation, restructuring, the sale of substantially all of our interests and/or assets or other corporate change, including during the course of any related due diligence process.

(e) Co-Branded Areas: Certain areas of the Services may be provided to you in association with third parties (“Co-Branded Areas”) such as licensors, sponsors or charities and may require you to disclose Personal Information to them. Such Co-Branded Areas will identify the third parties and may indicate if they have a privacy policy that applies to their collection and use of your information. If you elect to register for their products and/or services, communicate with such third parties or download their content or applications, at Co-Branded Areas, you may be providing your information to both us and the third party. Further, if you sign-in to a Co-Branded Area with a username and password obtained on the Services, your Personal Information may be disclosed to the identified third parties for that Co-Branded Area. We are not responsible for such third party’s data collection or practices and you should look to such third-party privacy policies for more information.

(f) Your California Privacy Rights: California Civil Code Section 1798.83 permits California residents who have supplied “personal information,” as defined in the statute, to the Services to (under certain circumstances) request and obtain certain information regarding our disclosure, if any, of certain information to third parties for their direct marketing purposes. We share information with our affiliates for those affiliates’ direct marketing purposes. California residents may obtain additional information about our compliance with this law by sending a letter to Square Enix, Inc., Attn: SEA Privacy Policy Administrator, 999 N. Sepulveda Blvd., 3rd Floor, El Segundo, CA 90245. Requests must include “California Privacy Rights Request” in the first line of the description and include your name, street address, city, state, and ZIP code. Please also include your email address and, if applicable, your Square Enix Account name. Please note that Square Enix is not required to respond to requests made by means other than through the provided mail address.

(g) Your European Privacy Rights: If you are a resident of the European Union, European Economic Area or Switzerland and do not consent to our SEA Privacy Policy or Terms of Service, or would like to ask us not to process your personal data (or not to provide it to third parties to process) for marketing purposes, please email us at na.privacypolicy@square-enix.com, or send a letter addressed to Square Enix, Inc., Attn: SEA Privacy Policy Administrator, 999 N. Sepulveda Blvd., 3rd Floor, El Segundo, CA 90245. We will make the requested changes in our active databases as soon as reasonably practical.

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4. What about Information I Disclose Publicly ?

(a) User Generated Content and Public Information: The Services may permit you to submit text, dialogue, ideas, photographs, user profiles, writings, music, video, audio recordings, computer graphics, pictures, data, questions, comments, suggestions, content created using an in-game tool, or other content, including Personal Information (collectively, “ User Content”) on blogs, message boards, through gameplay or other channels. We or others may store, display, reproduce, publish, distribute or otherwise use User Content online or offline in any media or format (currently existing or later developed) in perpetuity and may or may not attribute it to you. Others may have access to this User Content and may have the ability to share it with third parties. Please think carefully before deciding what information you share, including Personal Information, in connection with your User Content. Please note that Company does not control who will have access to the information that you choose to make public, and cannot ensure that parties who have access to such publicly available information will respect your privacy or keep it secure. We are not responsible for the accuracy, use or misuse of any User Content that you disclose or receive from third parties through the Services.

You may remove User Content you have posted on our forums by logging into your account, directly accessing your post, and using the editing tools in our forums (if available). Should you wish to edit or remove User Content you have previously posted publicly, you may contact us with your specific removal request. Please note that we are not required to remove your posted content or information if it has been rendered anonymous or if we are required by law to retain it.

(b) Name and Likeness: We may also publish your name, voice, likeness, username, profile image and other Personal Information that is part of your User Content, and we may use the content, or any portion of the content, for advertising, marketing, publicity and promotional activities.

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5. Do Third-Party Content and Links to Third-Party Services Appear on the Services ?

The Services may contain content that is supplied by a third party, and those third parties may collect your information when you interact with the Services or when web pages from the Services are served to you. In addition, when you are on the Services, you may be directed to other sites or services that are operated and controlled by third parties that we do not control, which may collect your information. We are not responsible for the data collection and privacy practices employed by any of these third parties or their sites. For example, if you “click” on a link, the “click” may take you off the Services onto a different site. These other sites may associate their Tracking Technologies with you, independently collect data about you, including Personal Information, and may or may not have their own published privacy policies. We encourage you to note when you leave our Services and to review the third-party privacy policies of all third-party locations and exercise caution in connection with them.

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6. What about Third-Party Applications that Appear on the Services ?

Third-party applications may be available via the Services (such as in-game advertising for other applications that can be accessed by you). The owners of these applications (“Third-Party Owners”) may collect information from you and may have their own policies and practices. We are not responsible for how Third-Party Owners or their applications collect or use your information. These Third-Party Owners may have their own terms of service, privacy policies or other policies and may ask you to agree to the same. We are not responsible for these third-party privacy policies or the practices of Third-Party Owners. Be sure to review any available policies before submitting any information to a third-party application or otherwise interacting with it and exercise caution in connecting with these applications.

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7. What about Third-Party Ads and Analytics on the Services ?

The Services may use third parties such as network advertisers and ad exchanges to serve targeted advertisements on the Services based on your behavior on and off of our Services, and may use third-party analytics, user research, or other similar service providers to evaluate and provide us and/or third parties with information about the use of the Services and viewing of ads and of our content. By installing and using our Services, you consent to these practices, including the sharing of data about you with these third parties and their own collection of such data as discussed further below. Network advertisers are third parties that display advertisements, which may be based on your visits to the Services and other locations you have visited. Third-party ad serving enables us and others to target advertisements to you or people like you for products and services in which you or people like you might be interested. The Services’ third-party ad network providers, the advertisers, the sponsors and/or traffic measurement services may themselves set and access their own Cookies and other Tracking Technologies on your Device and track certain behavioral information regarding users of your Device via a Device Identifier. These third-party Tracking Technologies may be set to, among other things: (a) help deliver advertisements to you or people like you that you or people like you might be interested in; (b) prevent you from seeing the same advertisements too many times; and (c) understand the usefulness to you of the advertisements that have been delivered to you. You acknowledge and agree that associated technology may access and use your Device and may set or change settings on your Device in connection with the associated operations. Note that any images (or any other parts of content) served by third parties in association with third-party ads or other content may serve as web beacons, which enable third parties to carry out the previously described activities. Third-party Cookies (including flash cookies) and other Tracking Technologies are governed by each third-party’s specific privacy policy, not this one. Our representations regarding our practices in this SEA Privacy Policy do not extend to the practices of these third-party advertisers and others or the use of the information that such third parties collect.

You may exercise choices regarding the use of cookies from Google Analytics by going to https://tools.google.com/dlpage/gaoptout or downloading the Google Analytics Opt-out Browser Add-on.

Please note that we adhere to the Digital Advertising Alliance’s Self-Regulatory Principles for Online Behavioral Advertising . You may view our list of third-party service providers, along with your opt-out choices, by visiting our Cookie Policy.

You may choose whether to receive certain interest-based advertising by submitting opt-outs. Some of the advertisers and service providers that perform advertising-related services for us and our partners may participate in the Digital Advertising Alliance ("DAA") Self-Regulatory Program for Online Behavioral Advertising. To learn more about how you can exercise certain choices regarding interest-based advertising, visit http://www.aboutads.info/choices, and http://www.aboutads.info/appchoices for information on the DAA’s opt-out program for mobile apps. Some of these companies may also be members of the Network Advertising Initiative (“NAI”). To learn more about the NAI and your opt-out options for their members, see http://www.networkadvertising.org/choices. Please be aware that, even if you are able to opt out of certain kinds of interest-based advertising, you may continue to receive other types of ads. Opting out only means that those selected members should no longer deliver certain interest-based advertising to you, but does not mean you will no longer receive any targeted content and/or ads (e.g., from other ad networks). We are not responsible for the effectiveness of, or compliance with, any third-parties’ opt-out options or programs or the accuracy of their statements regarding their programs.

Note that your browser settings may allow you to automatically transmit a "Do Not Track" signal to websites and online services you visit. There is no consensus among industry participants as to what "Do Not Track" means in this context. Like many websites and online services, we currently do not alter our practices when we receive a "Do Not Track" signal from a visitor's browser. To find out more about "Do Not Track," you may wish to visit http://www.allaboutdnt.com.

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8. How Do I Change My Information or Request Access to It ?

You are responsible for maintaining the accuracy of the information you submit to us, such as your contact information provided as part of registration. You have the right to access the Personal Information we have about you. You may review, correct or update Personal Information you have provided by logging in to your Square Enix Account or emailing us at na.privacypolicy@square-enix.com. We will respond to your access request within a reasonable time period. We may require additional information from you to allow us to confirm your identity.

Please note that it is not always possible to completely remove or delete all of your information from our databases and that residual data may remain on backup media or for other reasons. When you edit your Personal Information or change your preferences on the Services, information that you remove may persist internally for Company’s administrative purposes. You can stop all prospective collection of information by our Services by uninstalling and/or ceasing to use the Services. With respect to our mobile applications, you may use the standard uninstall process available as part of your applicable Device or via the appropriate application or app marketplace.

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9. How Do I Change My Communications Preferences ?

You may cancel or modify our email marketing communications you receive from us by following the instructions contained within our promotional emails or, where applicable, by logging into an account you have created for our Services. This will not affect subsequent access to the Services and your opt-out may be limited to certain types of emails.

Please note that we reserve the right to send you certain communications relating to your account or use of our Services, such as administrative and service announcements, and you will continue to receive these transactional account messages even if you opt-out from receiving our marketing communications.

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10. What about the Transfer of Information to the United States or Other Countries ?

Please be aware that information we collect, including Personal Information, may be transferred, processed, stored and used internationally, including in the United States, Canada, Japan and the European Union. The data protection laws in these countries may differ from those of the country in which you are located, and your Personal Information may be subject to access requests from governments, courts, or law enforcement. By using the Services, or providing us with any information, you consent to the transfer to, and processing, usage, sharing and storage of your information, including Personal Information, in other countries as set forth in this SEA Privacy Policy.

Company participates in the E.U.-U.S. and Swiss-U.S Privacy Shield Framework as set forth by the U.S. Department of Commerce regarding the collection, use, and retention of Personal Information from the European Union, European Economic Area and Switzerland. For the purpose of this Section 10, “Company” refers to the following legal entities only: Square Enix of America Holdings, Inc., Square Enix, Inc., Square Enix L.L.C., and Crystal Dynamics Inc. Company has certified that it adheres to the Privacy Shield’s Principles of notice; choice; accountability for onward transfer; security; data integrity and purpose limitation; access; and recourse, enforcement and liability. In accordance with its obligations under the Privacy Shield, and subject to the investigatory and enforcement powers of the U.S. Federal Trade Commission, Company hereby affirms its commitment to subject to the Privacy Shield Principles all Personal Information received from the European Union, European Economic Area and Switzerland in reliance on the Privacy Shield. This means that, in addition to Company’s other obligations under the Privacy Shield Principles, Company shall be liable to you for any third-party agent to which we transfer your Personal Information and who processes such Personal Information in a manner that violates the Privacy Shield Principles, unless Company can demonstrate that it is not responsible for the resulting damages.

Company is committed to resolving any complaints regarding your privacy and our collection and use of your information in accordance with the Privacy Shield Framework. For inquiries or complaints regarding the processing of Personal Information transmitted to Company from the European Union, European Economic Area or Switzerland, please contact us by sending a letter to: Square Enix, Inc., Attn: SEA Privacy Policy Administrator, 999 N. Sepulveda Blvd., 3rd Floor, El Segundo, CA 90245, or by emailing us at na.privacypolicy@square-enix.com. For any complaints we are unable to resolve directly, you may submit your complaint at no cost to you to JAMS at https://www.jamsadr.com/file-an-eu-us-privacy-shield-or-safe-harbor-claim . In the event there are residual complaints that have not been resolved by JAMS or any other means, you may seek a non-monetary remedy through binding arbitration to be provided to you in accordance with the Privacy Shield Principles.

To learn more about the Privacy Shield Framework, and to view Company’s certification, please visit https://www.privacyshield.gov/welcome. A list of companies certified under the Privacy Shield Framework is available at the following link: https://www.privacyshield.gov/list.

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11. What Should Parents Know about Children ?

We do not knowingly collect or store any Personal Information from Children without verifiable parental consent, as required by U.S. law. There may be instances, such as a sweepstakes, contest or promotion, in which we collect Personal Information from a Child in order to contact a parent and complete prize fulfillment.

If you are a parent or guardian of a Child under the age of 13 and believe he or she has disclosed Personal Information to us without your consent, please contact us at Square Enix, Inc., Attn: SEA Privacy Policy Administrator - COPPA, 999 N. Sepulveda Blvd., 3rd Floor, El Segundo, CA 90245. You can also contact us by email at na.privacypolicy@square-enix.com. We will delete the Child’s Personal Information from our records as soon as possible.

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12. What about Security ?

We take reasonable measures to help protect and secure your Personal Information. However, no data transmission over the Internet, mobile networks, wireless transmission or electronic storage of information can be guaranteed to be 100% secure. Please note that we cannot ensure the security of any information you transmit to us, and you use our Services and provide us with your information at your own risk. We will notify users of a data breach involving their unencrypted Personal Information by sending an email and/or prominently posting notice to the applicable Service.

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13. What if I have a Question or Complaint ?

If you have any questions or wish to file a complaint, please feel free to email us at na.privacypolicy@square-enix.com, or send a letter addressed to Square Enix, Inc., Attn: SEA Privacy Policy Administrator, 999 N. Sepulveda Blvd., 3rd Floor, El Segundo, CA 90245.

As previously mentioned, we are a licensee of ESRB’s Privacy Certified Program. If you believe that we have not responded to your inquiry or your inquiry has not been satisfactorily addressed, please contact ESRB Privacy Certified at http://www.esrb.org/privacy/contact.aspx, or ESRB, Attn: Vice President, Privacy Certified Program, 420 Lexington Ave., Suite 2240, New York, NY 10170. You may also e-mail them at privacy@esrb.org.

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14. What about Changes to the SEA Privacy Policy ?

We reserve the right to change this SEA Privacy Policy at any time. Any changes will be effective immediately upon the posting of the revised SEA Privacy Policy. However, we may require you to opt-in upon sign-in if we make material changes.

To the extent any provision of this SEA Privacy Policy is found by a competent tribunal to be invalid or unenforceable, such provision shall be severed to the extent necessary for the remainder to be valid and enforceable.

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