THE POKÉMON COMPANY PRIVACY NOTICE FOR THIS SITE

1.INTRODUCTION

This privacy notice (Privacy Notice) sets out the ways in which we, The Pokémon Company, and its affiliates, collect and use your personal data (your personal information) in connection with this official companion site of Pokémon Sleep and Pokémon GO Plus+ (this site) . It also explains what rights you have to access or change your personal data.

2. ABOUT US

The Pokémon Company is a company registered in Japan, with our address as set out below.
You can contact us as follows:
1. For users residing in Asia (except South Korea):
  The Pokémon Company
  Address: Roppongi Hills Mori Tower 8F,
  6-10-1 Roppongi, Minato-ku, Tokyo 106-6108 Japan
  Contact: https://support.pokemon.jp/form_app/inquiry/pokemon/ (Customer Support)
2. For users residing in South Korea:
  Pokémon Korea, Inc.
  Address: 4F 801, Sinsu-ro, Suji-gu, Yongin-si, Gyeonggi-do, Korea
  Email: mobilemaster@pokemonkorea.co.kr
3. For users residing outside Asia:
  The Pokémon Company International, Inc.
  Address: 10400 NE 4th Street, Suite 2800 Bellevue, WA 98004 USA
  Email: privacyquestions@pokemon.com

3. INFORMATION WE COLLECT ABOUT YOU

Information that you provide to us.
We don’t require personal information to use this site. If you choose not to disclose personal information, however, you will not be able to enjoy certain features of this site.
We will collect any information that you provide to us when you:
1. access certain features or functions in this site that require personal information;
2. make an inquiry, provide feedback, or make a complaint via email or our customer support site; and
3. submit correspondence to us via post, email, or our customer support site.
Information we collect about you.
1. Information contained in correspondence. We will collect any information contained in any correspondence between us. For example, if you contact us for customer support, we keep a record of that correspondence;
2. Technical data. We will also collect certain information about how you use this site and the browser and/or device that you use to access this site. This might include device information (such as your hardware model, operating system information, unique device identifiers, terminal identifier, advertisement identifier, terminal information, terminal setting information, et cetera), the data transmitted by your browser (such as your IP address, time zone settings, access status / HTTP status code, language settings, and time zone settings referral source), information about your interactions with this site, including time- and date-stamped information such as page views, requests, number of sessions, length of visit to this site, keystrokes, and similar information. This information may be collected by a third-party analytics service provider on our behalf and/or may be collected using cookies or similar technologies. For more information on cookies, please read paragraph 6 below;

4. HOW WE USE INFORMATION ABOUT YOU AND RECIPIENTS OF YOUR INFORMATION

We will use your information for the purposes listed below either on the basis of:
1. performance of your contract with us and the provision of our services to you;
2. your consent (where we request it);
3. our need to comply with a legal or regulatory obligation; or
4. our legitimate interests.
We use your information on the basis of the above (see paragraph 4.1) and for our legitimate business objectives, including for the following purposes:
1. To provide access to this site.
2. To allow you to access certain features of this site.
3. To process and facilitate transactions between us.
4. User and customer support. To provide customer service and support, deal with inquiries or complaints about this site, and to share your information with this site’s developers, IT support provider, and other services providers as necessary to provide customer support;
5. Analysis. To use data analytics to improve this site, products/services, marketing, customer relationships, and experiences;
6. Fraud and unlawful activity detection and prevention. To protect, investigate, and deter against fraudulent, unauthorized, or illegal activity, including identity fraud; to protect the rights and property of Pokémon, our agents, our customers, and others, including to enforce our terms, policies, rules, and agreements; to protect the safety and security of any person; and/or to protect the safety and security of Pokémon’s and our partners’ services, websites, and applications;
7. Compliance with policies, procedures, and laws. To enable us to comply with our policies and procedures and to enforce our legal rights, or to share your information with our technical and legal advisors, and to comply with laws or respond to lawful requests and legal process, including, for example, complying with a court order or subpoena.
If you are in the EU or the United Kingdom and have any concerns about our processing, please refer to details of “The Rights of Users in the EU or the United Kingdom” in paragraph 9 below.

5. WHO WE MIGHT SHARE YOUR INFORMATION WITH

In connection with the purposes and on the lawful grounds described above, we will share your personal information when relevant with third parties, such as:

Our service providers. Third-party vendors, consultants, and other service providers who work for us to support the internal operation of the site and related services and who access your personal information to do that work;
Corporate affiliates. The Pokémon Center Co., Ltd., The Pokémon Company International, Inc., Pokémon Korea, Inc., and Pokémon Singapore Pte. Ltd., based in Japan, the UK, USA, South Korea, and Singapore;
Prospective sellers and buyers of our business. In connection with or during negotiation of any merger, financing, acquisition, bankruptcy, dissolution, transaction, or proceeding involving sale, transfer, divestiture, or disclosure of all or a portion of our business or assets;
Other third parties (including professional advisers). Any other third parties (including legal or other advisors, regulatory authorities, courts, law enforcement agencies and government agencies) based in the UK, USA, Japan, and other countries/regions to enable us to enforce our legal rights, or to protect the rights, property, or safety of our employees, or where such disclosure may be permitted or required by law.

6. COOKIES AND SIMILAR TECHNOLOGIES

We, and others, use cookies, web beacons, device IDs, and similar technologies to ensure that you get the most out of this site. Cookies are small amounts of information in the form of text files which we store on the device you use to access this site. Cookies and similar technologies, such as device IDs, allow us, and others, to understand your and other users’ use of this site, provide functions on this site, and support and improve operations of this site.
Except where strictly necessary to provide the site, you may refuse cookies, web beacons, device IDs, and similar technologies.
Our website may contain content and links to other sites that are operated by third parties that may also operate cookies and other tracking mechanisms. We do not control these third-party sites or their tracking activities, and this Privacy Notice does not apply to them. Please consult the terms, conditions, and Privacy Notice of the relevant third-party site to find out how that site collects and uses your information and to establish whether and for what purpose it uses cookies.

7. HOW WE LOOK AFTER YOUR INFORMATION AND HOW LONG WE KEEP IT

We use appropriate technological and operational security measures to protect your information against unauthorized access or unlawful use.
We will retain your information for as long as is appropriate to provide you with the services that you have requested from us or for as long as we reasonably require to retain the information for our lawful business purposes, such as for legal compliance and enforcement purposes, and for resolving disputes. Actual retention periods depend on a variety of factors such as the type of product, the type and sensitivity of the data, business needs, customer expectations and needs, the types of available user controls, and the form in which the data is stored.

8. INTERNATIONAL TRANSFERS OF YOUR INFORMATION

Our company is located in Japan, and the personal information that we collect from you will predominantly be stored in the United States. This will involve a transfer of data outside the EEA or the United Kingdom.
Whenever we transfer your personal data from inside the EEA or the United Kingdom to outside of the EEA or the United Kingdom, the transfer will be based on at least one of the following:
1. Where we use certain service providers, we may use specific contracts approved by the European Commission that give personal data adequate protection. For further details, see European Commission: Model contracts for the transfer of personal data to third countries; and
2. Transfer to a country, territory, or specified sector within a country or territory that the European Commission has determined to ensure an adequate level of protection of personal data.
3. The transfer is necessary for the performance of a contract with you, is necessary for the conclusion or performance of a contract in your interest, or to take measures that you have requested, or is based on your explicit consent.
Please contact us using the contact details in paragraph 2 of this Privacy Notice if you want further information on the specific mechanism used by us when transferring your personal data out of the EEA or the United Kingdom.

9. THE RIGHTS OF USERS IN THE EU OR THE UNITED KINGDOM

If you are in the EU or the United Kingdom, you have certain rights with respect to the information that we hold about you, including:
1. the right to be informed of the ways in which we use your information, as we seek to do in this Privacy Notice;
2. the right to ask us not to process your personal data or to limit or cease processing or erase information we hold about you;
3. the right to request access to the information that we hold about you (or request that we transfer this to another service provider where technically feasible) in a structured, commonly used, machine-readable format, in certain circumstances;
4. the right to request that we correct or rectify any information that we hold about you which is out of date or incorrect;
5. the right to withdraw your consent for our use of your information in reliance of your consent;
6. the right to object to our using your information on the basis of our legitimate interests, and there is something about your particular situation which makes you want to object to processing on this ground; and
7. the right to lodge a complaint about us with the UK Information Commissioner’s Office (https://ico.org.uk/), you are also able to lodge a complaint with the relevant authority in your country/region of work or residence.
Please note that we may need to retain certain information for our own record-keeping and research purposes. We may also need to send you service-related communications relating to your user account even when you have requested not to receive marketing communications. There may be exceptions to these rights in certain circumstances, and where you cannot exercise a right due to an exception, we will provide that explanation. You may exercise your rights above by contacting us using the details in paragraph 2 of this Privacy Notice.

10. THIRD-PARTY LINKS

This site may include links to third-party websites, plug-ins, and apps. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites, plug-ins, and apps and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy notice of every third party you visit.

11. WHAT TYPES OF INFORMATION DO WE COLLECT ABOUT CHILDREN?

Visitors to this site, including children, can use this site, view content, and enjoy features without collection of any personal information (as defined under COPPA) other than technical identifiers used for the support of the internal operations of the site. Where consent of a parent is required by law, we will request it.

12. ADDITIONAL PRIVACY RIGHTS FOR CALIFORNIA RESIDENTS

This section provides you with additional disclosures required under California law.
If you are a California consumer whose personal information is collected through this site (“customer”), the California Consumer Privacy Act (“CCPA”) provides you with certain rights in respect to that personal information. In particular, you have a right to request that companies provide you with the following information:
1. The categories and specific pieces of personal information we have collected about you;
2. The categories or sources from which we collect personal information;
3. The purposes for collecting and using personal information;
4. The categories of third parties with which we share personal information;
5. The categories of personal information disclosed about you for a business purpose.
You also have a right to request that we delete personal information under certain circumstances, subject to a number of exceptions. Additionally, you have a right not to be discriminated against for exercising any of these rights.
You may exercise your rights above by contacting us using the details in paragraph 2 of this Privacy Notice. If you submit a request, we will require you to verify your identity where, if feasible, we may match your identification information with personal information we have about you, depending on the type of request made and verification measures proportional to the risk of the personal information involved with the request(s). There is no reasonable method by which we can verify your identity to the degree of certainty required by law for certain pieces of personal information, for example: unique identifiers such as cookie IDs, device ID, and IP address (where that information is not held by us in connection with directly identifiable information). There may be exceptions to these rights in certain circumstances, and where you cannot exercise a right due to an exception, Pokémon will provide that information. Pokémon will use reasonable efforts to fulfil your request within the response times of the applicable laws.
Pokémon does not sell your personal information from this site as defined by the CCPA and has not done so in the past 12 months.
In addition to the purpose in which your personal information is shared with other third parties (including professional advisers) in Section 5.1 (d), sharing includes sharing for business purposes that require access to our systems that hold personal information (such as supplying cloud data storage, maintaining the security of our systems, and providing customer support). In the past 12 months, we have disclosed to vendors all of the categories of personal information described in Section 3.
California Civil Code Section 1798.83 permits customers who are California residents to request certain information regarding disclosure of personal information to third parties for their own direct marketing purposes. We do not share our customers’ personal information with unaffiliated third parties for their own direct marketing purposes without your consent. For inquiries about our disclosure policy, please contact us using the details in paragraph 2.

13. DATA PROTECTION OFFICER

If you wish to contact our Data Protection Officer, please use the following details:
The Pokémon Company
Attention: Data Protection Officer
Address: Roppongi Hills Mori Tower 8F
6-10-1 Roppongi, Minato-ku
Tokyo 106-6108 Japan

14. CHANGES TO THIS PRIVACY NOTICE AND YOUR DUTY TO INFORM US OF CHANGES

We may amend this Privacy Notice at any time by changing the last updated date. If we make material changes to how we collect, use, or share your personal information, we will describe the changes, and, if required by law, seek your consent for such changes.

It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us by updating your profile account information or contacting us via the contact details in paragraph 2 of this Privacy Notice.

This Privacy Notice was updated on February 27, 2023.