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CALIFORNIA CONSUMER PRIVACY ACT POLICY (CCPA)

NAMCO USA INC.

www.namco.com

CALIFORNIA CONSUMER PRIVACY ACT POLICY (“Policy”)

 Pursuant to the California Consumer Privacy Act of 2018 (“CCPA”), NAMCO USA INC. (“Company,” “we” or “us”) is providing the following details regarding the categories of Personal Information that we collect, use, and disclose about California residents. Under the CCPA, “Personal Information” is information that identifies, relates to, or could reasonably be linked with a particular California resident or household.

 CATEGORIES OF PERSONAL INFORMATION COLLECTED

 We collect, and have collected within the preceding 12 months, the following categories of Personal Information. Please note a certain type of Personal Information in one category may overlap with Personal Information contained in one or more categories.

 

Category

 

 

Examples

 

 

A. Identifiers.

 

 

Real name, alias, contact information (such as mailing address, telephone number and e-mail address), username, and account name.

 

 

B. Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)).

 

 

A name, signature, contact information (such as mailing

address, telephone number and e-mail address), birth date, and payment card number.

 

 

C. Protected classification characteristics under California or federal law.

 

 

Characteristics of protected classifications under California law such as age and gender.

 

 

D. Commercial

Information

 

 

Transaction information and purchase history.

 

 

E. Internet or other similar network activity.

 

 

Browsing history, interaction with a website, Internet Protocol (IP) address, browser type, device type, Internet Service Provider (ISP), username, referring/exit pages, operating system, date/time stamp, pixel tags, and clickstream data.

 

 

F. Geolocation data.

 

 

Device location and approximate location derived from IP

address.

 

 

G. Audio, electronic, visual and similar information.

 

 

Photographs and audio and video recordings.

 

 


HOW WE COLLECT PERSONAL INFORMATION

 We collect the categories of Personal Information from the following sources:

 •  Directly from you. For example, when you give us feedback, participate in any of our polls, surveys, questionnaires, contests, sweepstakes or other promotions, link your social media account to your account with us, contact customer support, purchase goods or services at one of our business locations, or visit us at trade shows.

 •  Indirectly from you. For example, from observing your interactions with our websites or other online services we provide, from cookies and similar technologies used on or in connection with our websites (such as Google analytics) and social media services (like Facebook), or registering your arcade game or other entertainment game card.

 USE OF PERSONAL INFORMATION

 We use Personal Information for the purposes of operating, managing, and maintaining our business, providing our products and services, and accomplishing our business purposes and objectives, including to:

 •     Fulfill your requests, monitor purchases, and respond to your inquiries;

 •     Develop, improve, repair, and maintain our products and services, including websites and social media platforms;

 •     Personalize, advertise, and market our products and services;

•     Conduct research, analytics, and data analysis;

•     Establish and maintain user accounts and authenticate user identity;

•     Administer contests, sweepstakes, promotions, surveys, and questionnaires;

•     Maintain our property and our records, and undertake quality and safety assurance measures;

•     Conduct risk and security control and monitoring, and detect and prevent fraud;

•     Perform identity verification, accounting, audit, and other internal functions, such as internal investigations and record-keeping;

•     Carry out corporate transactions, such as mergers, joint ventures, or acquisitions; and

•     Comply with law, legal process, and internal policies, and exercise and defend legal claims.

 

SHARING OF PERSONAL INFORMATION\

Within the preceding 12 months, the following categories of Personal Information have been shared with certain third parties for business purposes:

Category A.  Identifiers

Category B.  Personal information

Category C.  Characteristics of protected classifications

Category D.  Commercial information

Category E.   Internet or network activity information

Category F.   Geolocation data

Category G.  Audio, electronic, visual and similar information

These categories of Personal Information are shared with:

•     Our affiliated entities.

•     Trusted third-party service providers.

 

SALE OF PERSONAL INFORMATION

We have not “sold” Personal Information within the preceding 12 months.

For purposes of this Privacy Policy, “sold” or “sale” means the disclosure of Personal Information for monetary or other valuable consideration but does not include, for example, the transfer of Personal Information as an asset that is part of a merger, bankruptcy, or other disposition of all or any portion of our business.

Cookies and Similar Tracking Technologies – We or our third party partners may store some information on your device or device hard drive as a "cookie" or similar type of file (such as pixels, tags, and similar technologies) to collect data related to usage of our websites and for the purpose of facilitating and enhancing your communication and interaction with the websites. Such data may include, without limitation, the address of the websites you visited before and after you visited our websites, the type of browser you are using, your Internet Protocol (IP) address, what pages in the websites you visit and what links you clicked on, and geolocation data. We use this information to help us maintain and enhance the efficiency and usefulness of our websites and may use it and other information about your Internet or other similar network activity for the purposes described in this Privacy Policy, such as to serve targeted advertising to you. Some of the information we collect may include data, such as IP address data or the identifiers associated with your device, that are unique to your computer or device (e.g., IDFA for iOS and Android ID for Android).

Cookies and similar items are not used by us to automatically retrieve personal information from your device without your knowledge. Please be advised that certain third parties that are beyond the scope of this Privacy Policy, such as advertisers, may collect information in connection with the Website. We are not responsible for the acts or omissions of such third parties.

If you want to stop or restrict the placement of cookies or flush any cookies that may already be on your computer or device, please refer to and adjust your web browser preferences. Further information on cookies is available at www.allaboutcookies.org. By deleting our cookies or disabling future cookies you may not be able to access certain areas or features of our Website or some of its functionality may be affected.

Clickstream Data – As you use the Internet, a trail of electronic information is left at each website you visit. This information, which is sometimes referred to as “clickstream data,” can be collected and stored by a website’s server. Clickstream data can tell us the type of device and browsing software you use and the address of the website from which you linked to one of websites. We may collect and use

clickstream data to anonymously determine how much time visitors spend on websites, how visitors navigate throughout websites and how we may tailor our websites to better meet consumer needs. This information will be used to improve our websites.

 

YOUR ACCESS, PORTABILITY AND DELETION RIGHTS

If you are a California resident, you may request that we:

(1)  Disclose to you the following information covering the 12 months preceding your request:

•     The categories of Personal Information we collected about you and the categories of sources from which we collected such Personal Information;

•    The specific pieces of Personal Information we collected about you;

•    The business or commercial purpose for collecting Personal Information about you; and

•     The business or commercial purpose for collecting Personal Information about you; and

•     The categories of Personal Information about you that we otherwise shared or disclosed, and the categories of third parties with whom we shared or to whom we disclosed such Personal Information (if applicable).

(2)  Delete Personal Information we collected from you. We may deny your deletion request if retaining the information is necessary for us or our service provider(s) to:

•     Complete the transaction for which we collected the personal information, provide a good or service that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform our contract with you.

•     Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities.

•     Debug products to identify and repair errors that impair existing intended functionality.

•     Exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law.

•     Comply with the California Electronic Communications Privacy Act (Cal. Penal Code §1546 et. seq.).

•     Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when the information's deletion may likely render impossible or seriously impair the research's achievement, if you previously provided informed consent.

•     Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us.

•     Comply with a legal obligation.

•     Make other internal and lawful uses of that information that are compatible with the context in which you provided it.

To make a request for the disclosure or deletion of Personal Information, please submit a verifiable consumer request to caprivacy@namco.com.

 

Only you, or a person registered with the California Secretary of State that you authorize to act on your behalf, may make a verifiable consumer request related to your personal information. You may also make a verifiable consumer request on behalf of your minor child.

 

Your verifiable consumer request must:

•     Provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative.

•     Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.

We cannot respond to your request or provide you with personal information if we cannot verify your identity or authority to make the request and confirm the personal information relates to you.

We will only use personal information provided in a verifiable consumer request to verify the requestor's identity or authority to make the request.

Any disclosures we provide will only cover the 12-month period preceding the verifiable consumer request's receipt. The response we provide will also explain the reasons we cannot comply with a request, if applicable.

We will respond to your request within a time period consistent with applicable law.

We do not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.

 

NON-DISCRIMINATION

We will not discriminate against California residents for exercising their rights under the CCPA.

 

CHANGES TO THIS POLICY

We may change or update this Policy from time to time. When we do, we will post the revised Policy on this page with a new “Last Updated” date.

 

CONTACT US

If you have any questions regarding this Notice, please contact us at privacy@namco.com.