Privacy Policy

[CONTENTS OF PRIVACY POLICY]

INTRODUCTION AND SCOPE OF POLICY

This Privacy Policy applies to Konami Gaming, Inc. and its direct subsidiaries; Konami Australia Pty. L (KAP); (collectively, “KGI”,  “we”, “our”, or “us”) in connection with KGI’s principal lines of gaming business (game design, development, manufacturing, sales, and services of casino games, gaming machines, provision of iGaming content, and casino management systems), (together, the “Gaming Products” and/or “Services”).

To better understand KGI privacy program and practices, we want you to know KGI operates internationally in the design, development, manufacturing, licensing, and customer services of Gaming Products and Services in order to support KGI customers in the gaming industry (“KGI Customers”).  All KGI Gaming Product’s end user (“Player”) personal data is collected and controlled by KGI Customers.   KGI has no control of the data collected and controlled by KGI Customers.

KGI processes the minimal data required to support the contractual obligations to the KGI Customers, provide customer support to KGI Customers, monitor Gaming Product performance by collecting Player identifiers, wager outcomes and metrics of KGI Gaming Products and/or Services.

We do not sell any data or monetize any data by selling it to a third party for advertising.

This Privacy Policy covers when you:

• Visit a KGI website that links to the Privacy Policy
• The processing of identifiable information or data retained by KGI.
• Interact with KGI as a representative of a KGI Customer that has (or is considering) a business relationship with KGI either as a customer or a supplier.
• Provide us with feedback about our Products or Services.
• Receive sales or marketing communication from us, including emails or telephone calls.
  

This Privacy Policy does not cover how data collected by KGI Customers using KGI Gaming Products and/or Services is controlled and processed by such KGI Customers. All questions or concerns about the personal information collected or processed by KGI Customers should be directed to the KGI Customer that collects and controls such data.

KGI employees and job applicants will be advised by KGI Human Resources about why and how their personal information is used and protected.

CHILDREN

KGI Sites and KGI Products and Services are not intended for persons under 18 years of age. No one under age 18 may provide any information to or on a KGI website.  We do not knowingly collect personal information from children under the age 18 unless we have obtained consent from a parent or guardian. If you are under the age of 18, please do not attempt to register for the Products or Services or send any personal information about yourself to us.  If we learn we have collected or received personal information from a child under 18 without verification of parental consent, we will delete that information.  If you believe we have mistakenly or unintentionally collected personal information of a child without appropriate consent, please contact us by using the information in the “Contact Information” section below and we will take steps to delete their personal information from our systems.  

California residents under 16 years of age may have additional rights regarding the collection and sale of their personal information. Please see Your California Privacy Rights for more information.

INFORMATION COLLECTION PROCESSES

KGI collects personal information where required by purpose or legal basis.  KGI is committed to data minimization and protection of the data processed in association with KGI Gaming Products and Services. 

KGI collects KGI Customer personal information for the express purpose of providing and supporting KGI Gaming Products and/or Services to the KGI Customer, including, but not limited to, when information is requested regarding KGI Gaming Products and/or Services, contracting, account and customer service interactions.

KGI will assist KGI Customers with monitoring KGI Gaming Products and/or Service that involve game metric measurements, wager reporting, or technical assistance.  In connection with providing KGI Customers with technical assistance, related to KGI Gaming Products and/or Services, KGI Customers may disclose Player information. In doing so, Player data will be anonymized through data masking or removing Players’ identifiers and personal information.

Below we describe the types of interactions where we collect information, the types of information that is collected in those situations, the reasons for the collection and the purpose and legal basis for such collection.

When you request information from us or are a KGI Customer.  When you fill out a contact form or otherwise contact us to express interest in obtaining information about KGI and/or you are interested in the KGI Gaming Products and/or Services with KGI. In these cases, we will ask you to provide us with your contact information such as name, email address, telephone number, company name, job level or role, functional role, and/or mailing address. 

• Purpose and Legal Basis Under Data Protection Laws.  We process your personal information in reliance on our legitimate interests or your consent (where required by law) to:
  • Provide you with information about our Products and/or Services, as requested and through marketing emails, in accordance with your marketing preferences.
  • Manage your organization’s account, including invoices and other account-related issues.
  • Provide KGI Customers with customer service support per the terms of the contract with KGI.
  • Communicate with you and fulfill your request for information or support. 

When you are a Player of KGI Gaming Products and/or Services with a KGI Customer.  When processing anonymized Player data, IP Address, game and/or system metrics, wager reporting, and providing technical support, while interacting with KGI Gaming Products and/or Services.  

• Purpose and Legal Basis Under Data Protection Law. We process this information in reliance on our legitimate interests to: 
  • Support KGI Customers to facilitate, operate, and maintain KGI Gaming Products and/or Services.
  • Fulfill the contractual requirements for KGI Customers.

When you are a supplier to KGI.  If you are a representative of a company that provides KGI with products or services (“Suppliers”), we collect your business contact information including your name, business email, telephone number, and company name.

• Purpose and Legal Basis Under Data Protection Law. We process your personal information in reliance on our legitimate interests to: 
  • Manage Supplier’s accounts, including invoicing and other account-related issues.
  • Communicate with you and respond to your inquiries.

When you are a job applicant to KGI.  If you have applied for employment with KGI, job application information is governed by Human Resource policies and the KGI Human Resources department.  Please contact the Human Resources department through the Contact Us Page.

When you are an employee of KGI. If you are an employee at KGI, employee information is governed by Human Resource policies and the KGI Human Resource department. Please contact the Human Resources department through the Contact Us Page.

AUTOMATIC DATA COLLECTION TECHNOLOGIES

When you Access our websites or Content.  As is true of most other websites, the KGI website collects certain information automatically.  The information may include internet protocol (IP) addresses, the region or general location where your computer or device is accessing the internet, browser type, operating system and other usage information about the use of the KGI’ websites, including the pages you view on them.

As you navigate through and interact with our website, we may use automatic data collection technologies to collect certain information about your equipment, browsing actions, and patterns, including:

• Details of your visits to our website, including traffic data, location data, logs, and other communication data and the resources that you access and use on a KGI website.

• Information about your computer and internet connection, including your IP address, operating system, and browser type.

The information we collect automatically may include personal information, or we may maintain it or associate it with personal information we collect in other ways or receive from third parties. It helps us to improve our website and to deliver a better and more personalized service.

The technologies we use for this automatic data collection may include:

• Cookies (or browser cookies). A cookie is a small file placed on the hard drive of your computer. You may refuse to accept browser cookies by activating the appropriate setting on your browser. However, if you select this setting you may be unable to access certain parts of our website. Unless you have adjusted your browser setting so that it will refuse cookies, our system will issue cookies when you direct your browser to our website.

• Flash Cookies. Certain features of our website may use local stored objects (or Flash cookies) to collect and store information about your preferences and navigation to, from, and on our website. Flash cookies are not managed by the same browser settings as are used for browser cookies.

• Web Beacons. Pages of our website and our emails may contain small electronic files known as web beacons (also referred to as clear gifs, pixel tags, and single-pixel gifs) that permit the Company, for example, to count users who have visited those pages or opened an email and for other related website statistics.

Third-Party Use of Cookies and Other Tracking Technologies

Some content or applications on KGI’s websites are served by third parties, including Google, advertisers, and servers, content providers, and application providers. These third parties may use cookies alone or in conjunction with web beacons or other tracking technologies to collect information about you when you use our website. The information they collect may be associated with your personal information or they may collect information, including personal information, about your online activities over time and across different websites and other online services. They may use this information to provide you with interest-based (behavioral) advertising or other targeted content.  We do not control these third parties' tracking technologies or how they may be used. 

In some jurisdictions in the United States, the countries in the EEA, the UK, Switzerland, this type of information is seen as protectable personal information under the privacy laws applicable in these regions.

Purpose and Legal Basis Under Data Protection Law.  We process this personal information in reliance on our legitimate interests to:

• To present our website and its contents to you.
• To provide you with information that you request from us.
• Restrict visits to KGI website(s) based on Industry age requirements.
• Better understand the visitors and users who come to our websites, where they come from, and what content on our websites is of interest to them. We use this information for our internal analytics purposes and to improve the quality and relevance of our websites to such persons.
• Provide, operate, and maintain our websites, including providing access to content you have requested, such as a newsletter or event announcement, job applications or inquiries, and displaying country-specific information.
• Protect the security and prevent misuse of our website by tracking use of accounts and activity, investigating and auditing log activity, and enforcing our terms and policies.
  

HOW WE DISCLOSE YOUR DATA AND PERSONAL INFORMATION

KGI may disclose any of the categories of personal information described above to affiliates within the KGI group of companies where it is necessary to fulfill customer support requests, marketing, technical operations, every registration, and account management purposes.

KGI may disclose certain categories of personal information described above to third party service providers or vendors contracted to provide services on our behalf (examples include information technology providers, hosting, data analytics, event services, customer support, email fulfillment, data management, and payment services). These third-party service providers may use personal information we provide to them only as instructed by KGI.

Where your organization is a customer of KGI, we may disclose your personal information to relevant people within your organization.  For example, we may share the names of individuals within your organization seeking assistance or other support from KGI when it is relevant to providing KGI Gaming Products and/or Services.

KGI may share your personal information with certain partners that offer our Products and/or Services in jurisdictions where KGI is not licensed to provide such Products and/or Services directly to you.

KGI may disclose data if we have a good faith belief that such action is necessary to (a) conform to legal requirements or comply with legal processes; (b) protect and defend our rights or property; (c) enforce our terms and policies; (d) act to protect the interests of our customers, users, and others for fraud protection and other risk management purposes; and (e) if we are going through a business transition, such as a merger, acquisition by another company, or a sale of all or a portion of our assets, your personal information may be among the assets transferred, provided  we inform the transaction partner (or its agents and advisors) that it must use your personal information only for the purposes disclosed in this Privacy Policy.   KGI may also disclose your information to other unaffiliated third parties at your direction and with your consent.

HOW WE PROTECT DATA AND PERSONAL INFORMATION

KGI is committed to ensuring the confidentiality, integrity, and availability of all information assets, including protecting personal information. We use technical and organizational measures to provide a level of security appropriate to the nature of the data and the risks that are presented by processing your personal information. Specifically, these measures include regular authentication protocols, cybersecurity awareness programs and training, infrastructure monitoring, risk assessments, business continuity, availability, and incident response management. Information security is never guaranteed, and KGI Customers and Customers’ employees are responsible for maintaining the security of your passwords or other forms of authentication involved in accessing password-protected or secured resources.

INTERNATIONAL DATA TRANSFERS

Your information may be transferred to and processed in countries other than your own. These countries may have different data protection laws.

DATA PRIVACY RIGHTS

Depending on where you are located and how you interact with KGI, you may have certain legal rights over the personal information we hold about you, subject to local privacy laws.  If you have any questions regarding your data privacy rights, we encourage you to contact your local governmental authorities entitled to interpret and enforce the applicable data and personal information privacy laws in your jurisdiction. 

Globally, privacy rights include some or all the following:

Right to Be Informed

• Individuals have the right to know:
• What personal data is collected
• Why it is collected
• How it will be used
• Who it will be shared with

• Businesses must provide clear and accessible privacy notices.

 Right of Access

• Individuals can request access to their personal data.
• Businesses must provide a copy of the data and explain:
• What data is held
• Why it is being processed
• How long it will be retained

Right to Rectification

• Individuals can request that inaccurate or incomplete personal data be corrected.

Right to Erasure ("Right to be Forgotten")

• Individuals can request deletion of their personal data in certain situations:
• When data is no longer necessary
• When consent is withdrawn
• When data was unlawfully processed

Right to Restrict Processing

• Individuals can limit how their data is used without requiring it to be deleted entirely.

Right to Data Portability

• Individuals can receive their personal data in a structured, commonly used format and transfer it to another organization.

Right to Object

• Individuals can object to data processing for:
• Direct marketing
• Profiling
• Legitimate interest grounds

Rights Related to Automated Decision-Making and Profiling

• Individuals have the right to:
• Not be subject to decisions based solely on automated processing
• Request human intervention
• Express their point of view and contest the decision

Right to Withdraw Consent

• If data processing is based on consent, individuals can withdraw it at any time.

Right to Lodge a Complaint

• Individuals can file a complaint with a relevant data protection authority if they believe their rights have been violated.

Right to Non-Discrimination

• Individuals must not be discriminated against for exercising their privacy rights.

Exercising your Privacy rights. To exercise your rights with respect to information covered by this Privacy Policy, please contact us using the contact details at the bottom of this Privacy Policy.  You must provide the information listed in the Request Portal so that KGI can verify your identity.  KGI will take steps to verify your identity, including validating your name and the email you use when interacting with KGI.  You may also authorize another person to submit a request to exercise your rights by providing written permission in conjunction with the submission of the requested information. We will acknowledge your request and provide a follow-up substantive response within a time period permitted by appliable law.  If KGI needs more time to fulfill a request, we will notify you. If KGI denies a request, we will provide reasons for that denial.  KGI does not respond to mass request disseminators.

US and International Laws That Shape These Rights

SUPPLEMENTAL TERMS FOR VARIOUS JURISDICTIONS

California: Pursuant to the CCPA, KGI supplements its data processing disclosures in the link here.

Australia: Personal data collected, stored, used, and/or processed by KGI as described in this Policy, is collected, stored, used, and/or processed in accordance with the Australian Privacy Act 1988 and the Australia Privacy Principles.  If you are dissatisfied with our handling of a complaint or do not agree with the resolution proposed by us, you may make a complaint to the Office of the Australian Information Commissioner (OAIC) by contacting the OACIC using the methods listed on their website OAIC. Alternatively, you may request that we pass on the details of your complaint to the OAIC directly. Please see the Konami Gaming Inc. Australian Privacy Act.

No Discrimination.  KGI will not discriminate against you for exercising your applicable privacy rights. KGI does not make decisions based solely on automated processing that produce legal or similarly significant effects as part of the processing activities covered by this Privacy Policy.

CHANGES TO THIS PRIVACY POLICY

This Privacy Policy may be amended or revised from time to time at the discretion of KGI. Changes to this Privacy Policy will be posted on the website and links to the Privacy Policy will indicate that the statement has been changed or updated. If we propose to make any material changes, we will provide notice on this page prior to the change becoming effective. We encourage you to periodically review this Privacy Policy for the latest information on our privacy practices.

CONTACT INFORMATION

If you have questions or complaints regarding this Policy or about the KGI privacy practices, please contact:

Konami Gaming, Inc.
585 Konami Circle
Las Vegas, NV  89119