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 Pokémon UNITE (our App). It also explains what rights you have to access or change your personal data.

2. ABOUT US

1. 2.1The Pokémon Company is a company registered in Japan, with our address as set out below.
2. 2.2You can contact us as follows:

   The Pokémon Company International, Inc.

   Attention :

   Pokémon UNITE

   Address :

   10400 NE 4th Street, Suite 2800 Bellevue, WA 98004 USA

   Email :

   privacyquestions@pokemon.com

3. INFORMATION WE COLLECT ABOUT YOU

1. 3.1Information that you provide to us.

   We don’t require personal information to use the App. If you choose not to disclose personal information, however, you will not be able to enjoy certain features of the App.

   1. 3.1.1We will collect any information that you provide to us when you:

      ( a )

      access certain features or functions in our App that require personal information;

      ( b )

      make an inquiry, provide feedback, or make a complaint via email or our customer support site; and

      ( c )

      submit correspondence to us via post, email, or our customer support site.

   2. 3.1.2The information you provide to us when you use our App will include (depending on the circumstances):

      ( a )

      Identity data. Country or region where you are located and date of birth; and

      ( b )

      Player profile data. You may also provide a username and language preferences.

   NOTE: Do not use your real name, initials, or other customer-identifiable information in a username. This includes:

   • Any in-game ID, passwords, et cetera
   • Inquiry information
   • Any other personal information
2. 3.2Information we collect about you.

   ( a )

   Transactional data. We will collect information related to your transactions through our App, including the date and time, the amounts consumed, and other related transaction details;

   ( b )

   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;

   ( c )

   Technical data. We will collect certain information about how you use our App and the device that you use to access our App, even where you have not created an account or logged in. This might include your geographical location, device information (such as your hardware model, operating system information, unique device identifiers, terminal identifier, advertisement identifier, terminal information, terminal setting information, et cetera), advertising ID (in apps that display advertising), unique player identifiers, such as a support ID and key or transfer password, player ID, player key, access key, 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 the App, including time- and date-stamped information such as page views, requests, number of sessions, number of downloads, users’ game progress, and gameplay-related data including game errors, in-app purchases, length of visit to the App, keystroke logs, and similar information. For more information on cookies, please read paragraph 7 below;

   ( d )

   App permissions. We may request permission to access apps and certain features on your device.

   ( e )

   Audio recordings and text communications. We will retain a record of your text communications through the App for the limited use of investigating compliance with user terms on the basis of user reports. We also record audio chat through the App, which is then automatically transcribed, for the same purpose. Audio recordings are deleted immediately after transcription. Both text and voice chat information will not be used for any purpose other than investigating compliance with App terms.

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

1. 4.1We use your information for the following purposes:

   ( a )

   To provide access to our App. To provide you with access to our App in a manner convenient and optimal and with personalized content relevant to you and to allow you to have a record of your gameplay within the App;

   ( b )

   To allow you to access certain App features. To enable you to access features such as gameplay;

   ( c )

   To enable you to play with other players. We will use the information you have provided (such as your username and language settings) to enable you to play with other players;

   ( d )

   To process and facilitate transactions between us. We will use your information to process transactions and payments;

   ( e )

   User and customer support. To provide customer service and support, deal with inquiries or complaints about our App, and to share your information with our App developers, IT support provider, and payment services provider as necessary to provide customer support;

   ( f )

   To send push notifications. To send you push notifications about your use of our App, our news, events, new App features, products, or services that we believe may interest you, provided that we have the requisite permission to do so;

   ( g )

   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;

   ( h )

   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.

5. WHO WE MIGHT SHARE YOUR INFORMATION WITH

1. 5.1In connection with the purposes and on the lawful grounds described above, we will share your personal information when relevant with third parties, such as:

   ( a )

   App users that you play. Other App users who you play with;

   ( b )

   Our service providers. Third-party vendors, consultants, developers, and other service providers who work for us and access your personal information to do that work;

   ( c )

   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;

   ( d )

   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;

   ( e )

   Ad network. Service providers that deliver information to you via ad network system regarding Pokémon’s current or future products and services.

   ( f )

   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. USE OF INFORMATION COLLECTION MODULES FROM THIRD PARTIES

We may use the Information Collection Module of a third party to investigate trends in the use of the App, effectively operate the App, prevent fraud, and advertise to customers. In this case, the following organizations may be provided with customer information for this purpose. (Please also refer to the privacy notice set by the relevant company.):
[Push Notifications] Google Inc. (Google Firebase)
[Voice Chat; Analytics; Game Performance and Security] (Tencent Holdings Ltd.)

7. COOKIES AND TRACKING

1. 7.1We, and others, use cookies, web beacons, device IDs, and other tracking mechanisms to ensure that you get the most out of our App and to provide us information about your use of the App. Cookies are small amounts of information in the form of text files which we store on the device you use to access our App. Cookies and other tracking mechanisms, such as device IDs, allow us, and others, to monitor your use of the software, simplify your use of our App, and to help us and others associate the mobile devices you use, your activities across websites, and your browsers for advertising purposes.
2. 7.2Our 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.

8. HOW WE LOOK AFTER YOUR INFORMATION AND HOW LONG WE KEEP IT FOR

1. 8.1We use appropriate technological and operational security measures to protect your information against unauthorized access or unlawful use.
2. 8.2We 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.

9. INTERNATIONAL STORAGE LOCATION

Our company is located in Japan, and the personal information that we collect from you will predominantly be stored in Canada.

10. THIRD-PARTY LINKS

Our App 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?

We do not collect any personal information from users under the age of 16 (“Child” or “Children”). If a parent believes we have unintentionally collected their Child’s personal information, they may contact us at customer support to request the deletion of the information.

12. ADDITIONAL PRIVACY RIGHTS FOR CALIFORNIA RESIDENTS

1. 12.1This section provides you with additional disclosures required under California law.
2. 12.2If you are a California consumer whose personal information is collected through the App (“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:

   ( a )

   The categories and specific pieces of personal information we have collected about you;

   ( b )

   The categories or sources from which we collect personal information;

   ( c )

   The purposes for collecting and using personal information;

   ( d )

   The categories of third parties with which we share personal information;

   ( e )

   The categories of personal information disclosed about you for a business purpose.

3. 12.3You 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.
4. 12.4You 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 fulfill your request within the response times of the applicable laws.
5. 12.5Pokémon does not sell your personal information as defined by the CCPA and has not done so in the past 12 months.
6. 12.6In addition to the purpose in which your personal information is shared with other third parties (including professional advisers) in Section 5.1 (f) and 6 above, 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.
7. 12.7California 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

1. 13.1If 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 28,2021.

*Asia

• Republic of India
• Republic of Indonesia
• Republic of Singapore
• Kingdom of Thailand
• Islamic Republic of Pakistan
• Republic of the Philippines
• Brunei Darussalam
• Malaysia
• Republic of Korea
• Hong Kong
• Macau
• Taiwan
• Japan