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FOOTBALL MANAGER PRIVACY POLICY

SEGA is committed to protecting and respecting your privacy.

This policy (together with our Terms of Service, End User Licence Agreement for FM
(as defined below) and any other documents referred to in it) sets out the basis on
which any personal data we collect from you, or that you provide to us, will be
processed by us. Please read the following carefully to understand our views and
practices regarding your personal data and how we will treat it.

By registering your details with SEGA in relation to Football Manager 2018 or any
of the games in the Football Manager series on any platform including Football
Manager Touch and Football Manager Online ("FM") or any other SEGA website or
websites owned or operated by SEGA affiliates including the official Football
Manager website ("Websites") you consent to the use and transfer of your personal
information inside and outside the EEA. Additionally, SEGA collects data in respect
of its Data Subjects (as defined below) for inclusion in FM, as described below.

This privacy policy sets out how SEGA will use any information about you that it
gathers. For the purposes of this privacy policy any reference to 'websites' shall
also include WAP sites managed by SEGA. Please note that certain SEGA websites may
have a privacy policy specific to that website which may differ to this privacy
policy.
1. INFORMATION FOR CUSTOMERS

INFORMATION WE MAY COLLECT FROM YOU


Automatic information: we automatically collect general data to allow creation of
game statistics, website statistics, such as page impressions, but this data cannot
be used to track the movements of any individual user in FM or the Websites.

Information that you provide to us: generally, your use of FM or the Websites does
not require you to provide any personal information. However, in certain
circumstances where we do ask for your personal information we do collect and
process such personal information in accordance with the explanation below.

Data collection can occur in a number of different ways, including, but not limited
to:

Information that you provide by filling in forms. This includes information


provided at the time of registering to use FM or the Websites, subscribing to our
services, posting material or requesting further services. We may also ask you for
information when you enter a competition or promotion sponsored by SEGA or when you
report a problem with FM or the Websites.
If you contact one of SEGA's product support operatives, we may keep a record of
that correspondence.
SEGA may also ask you to complete surveys that we use for research purposes,
although you do not have to respond to them.
Details of transactions you carry out through our sites and of the fulfillment of
your orders.
Details of your visits to our Websites, including, but not limited to, traffic
data, location data, weblogs and other communication data, whether this is required
for our own billing purposes or otherwise and the resources that you access.
Registering with SEGA's online product support service.
IP addresses
We may collect information about your computer, including where available your IP
address, operating system and browser type, for system administration and to report
aggregate information to our advertisers. This is statistical data about our users'
browsing actions and patterns, and does not identify any individual.

Cookies
Websites operated by SEGA use cookies. These store a string of unique numbers on
your hard drive which allow only the SEGA websites to identify you or to otherwise
monitor your activity within SEGA's websites. Cookies are not required for the
websites to work but will enhance your experience. They help us to improve our
sites and to deliver a better and more personalised service. We do not store any
personal data in these cookies, just a unique number that identifies you to us. You
can block cookies by activating the setting on your browser which allows you to
refuse the setting of all or some cookies. However, if you use your browser
settings to block all cookies (including essential cookies) you may not be to
access all or parts of our sites. Unless you have adjusted your browser setting so
that it will refuse cookies, our system will issue cookies as soon you visit our
Websites. For more information on this procedure it is recommended that you contact
the developer of your browser.

USES MADE OF THE INFORMATION


We use information held about you in the following ways:

To ensure that content from our Websites is presented in the most effective manner
for you and for your computer.
To provide you with information, products or services that you request from us or
which we feel may interest you, where you have consented to be contacted for such
purposes.
To carry out our obligations arising from any contracts entered into between you
and us.
To allow you to participate in interactive features of our service, when you choose
to do so.
To notify you about changes to our service.
We may also use your data, or permit selected third parties to use your data, to
provide you with information about goods, services, special offers and promotions
which may be of interest to you.

If you are an existing customer, we will only contact you by electronic means (e-
mail or SMS) with information about goods and services similar to those which were
the subject of a previous sale to you.

If you are a new customer, and where we permit selected third parties to use your
data, we (or they) will contact you by electronic means only if you have consented
to this.

If you do not want us to use your data in this way, or to pass your details on to
third parties for marketing purposes, please tick the relevant box situated on the
form on which we collect your data.

YOUR RIGHTS
You have the right to ask us not to process your personal data for marketing
purposes. We will usually inform you (before collecting your data) if we intend to
use your data for such purposes or if we intend to disclose your information to any
third party for such purposes. You can exercise your right to prevent such
processing by checking certain boxes on the forms we use to collect your data. You
can also exercise the right at any time by contacting us (please see below for our
contact details).

Our sites may, from time to time, contain links to and from the websites of our
partner networks, advertisers and affiliates. If you follow a link to any of these
websites, please note that these websites have their own privacy policies and that
we do not accept any responsibility or liability for these policies. Please check
these policies before you submit any personal data to these websites.

2. INFORMATION FOR FM DATA SUBJECTS


INFORMATION WE MAY COLLECT FROM YOU
FM uses a complex, detailed and accurate database to simulate real-world football
performance. The FM database comprises data compiled from and using or representing
real-life footballers, managers, referees, team coaching and medical staff (Data
Subjects) from around the world. The database includes full names of the Data
Subjects as well as characteristics, behaviour and likenesses as they relate to the
Data Subjects footballing career in the real world.

Specifically, SEGA collects some or all of the following personal data in respect
of each Data Subject:

Given first name and surname;


Date of birth;
Age;
Nationality;
Head shot photograph;
Details about the Data Subjects club, which may include contract type and
expiration date, team and game statistics;
Estimated gross salary, earnings per week and number of bonuses awarded;
Physical attributes, such as hair colour, height, weight and body type;
Medical history where Data Subjects have made such medical history public;
Various technical, mental and physical attributes.
(together, the "FM Data").

USES MADE OF FM DATA


The FM Data is compiled by SEGAs scouting network which comprises approximately
1,300 individuals across 50 countries (the "Network"). The Network collects the FM
Data in three ways: (i) through attendance at football matches where Data Subject
performance is observed and rated; (ii) through publicly available information such
as newspapers, match programmes, websites and TV programmes; and (iii) through
SEGAs relationships with various third parties such as football clubs, leagues and
football associations.

Once the FM Data has been compiled by the Network, SEGAs in-house research team
review the FM Data and data sources. Subjective sets of ratings which cover
physical, mental and technical attributes of Data Subjects are built up over a
period of weeks, months and years to provide a full profile by watching these
players play in matches or in training sessions, reading match reports on various
types of media, and by referencing SEGAs forums where discussions are to be found
on each set of data within each country. Once the FM Data has been verified and
cross-referenced by SEGAs in-house researchers, it is then integrated within the
FM database to provide customers with a rich and realistic football management
experience.

Additionally, Data Subjects are rated by the Network in more than 30 categories
based on technical ability (for example: dribbling and corner-taking), mental
ability (for example: aggression and decision-making) and physical ability (for
example: balance and agility). These ratings are intended to reflect the Data
Subjects ability, but SEGA makes no guarantee, warranty or representation as to
the accuracy of such ratings at any time.

YOUR RIGHTS
Whilst SEGA takes great care to verify the accuracy of the FM Data, and takes
stringent security measures to protect such data, Data Subjects have the right to
ask us: (i) to amend the FM Data; or (ii) not to process the FM Data within the FM
database. You can exercise your right by contacting SEGA at the following email
address: notifications@sigames.com
SEGA shall aim to remove or amend the FM Data (as applicable) from the FM database
within five (5) working days upon receipt of the Data Subjects written request.

3. WHERE WE STORE CUSTOMER PERSONAL DATA AND FM DATA


The data that we collect from customers and Data Subjects may be transferred to,
and stored at, a destination outside the European Economic Area ("EEA"). It may
also be processed by staff operating outside the EEA who work for us or for one of
our suppliers. Such staff may be engaged in, among other things, the fulfilment of
your order, the processing of your payment details and the provision of support
services. By submitting your personal data, you agree to this transfer, storing or
processing. SEGA will take all steps reasonably necessary to ensure that your data
is treated securely and in accordance with this privacy policy.

Where we have given you (or where you have chosen) a password which enables you to
access certain parts of our sites, you are responsible for keeping this password
confidential. We ask you not to share a password with anyone.

Unfortunately, the transmission of information via the internet is not completely


secure. Although we will do our best to protect your personal data, we cannot
guarantee the security of your data transmitted to our sites; any transmission is
at your own risk. Once we have received your information, we will use strict
procedures and security features to try to prevent unauthorised access.

4. DISCLOSURE OF CUSTOMER INFORMATION AND FM DATA


We may disclose your personal information to any member of our group, which means
our subsidiaries, our ultimate holding company and its subsidiaries, as defined in
section 1159 of the UK Companies Act 2006.

We may disclose publically available FM Data to certain third parties through


strategic partnerships such as football clubs or sports analytic consultancies.

We may disclose your personal information to third parties:

In the event that we sell or buy any business or assets, we may disclose your
personal data to the prospective seller or buyer of such business or assets.

If SEGA or substantially all of its assets are acquired by a third party, personal
data held by it about its customers will be one of the transferred assets.

If we are under a duty to disclose or share your personal data in order to comply
with any legal obligation, or in order to enforce or apply our terms of use
(http://www.sega.co.uk/terms) and other agreements; or to protect the rights,
property, or safety of SEGA, our customers, or others. This includes exchanging
information with other companies and organisations for the purposes of fraud
protection and credit risk reduction.

5. ACCESS TO INFORMATION
You have the right to request a copy of the personal information that SEGA holds
about you and to have any inaccuracies corrected at your request. SEGA charges 10
for requests for information to be processed. Please send requests, and payment by
cheque or postal order (please do not send coins or bank notes), to:

Customer Services

SEGA Europe Ltd

27 Great West Road

Brentford
Middlesex

TW8 9BW

You may also request that we remove any of your personal information from our
database at any time. Data Subjects should follow the separate procedure detailed
in paragraph 2 (Your Rights) above. Similarly, if and when we email newsletters or
other updates to you, we will provide you with the opportunity to unsubscribe from
such services.

6. MISCELLANEOUS
If at any time you wish to amend the information held by SEGA, simply log in to the
SEGA website and change your information by clicking Edit Profile at the top right
of the homepage.

If you forget your password simply enter your email address and it will be sent to
you. For your security SEGA recommends that you do not use a simple password that
will be easy for others to guess.

Privacy is a two way process. You need to take steps to maintain your privacy and
should respect the privacy of others.

7. CHANGES TO OUR PRIVACY POLICY / GOVERNING LAW


We reserve the right to change this privacy policy at any time without notice, and
any such changes will appear in the copy of this privacy policy available on SEGA's
website. This agreement is governed by the laws of England and Wales.

8. CONTACT DETAILS
If you have any questions about this privacy statement or the practices of this
site, please contact SEGA:

United Kingdom Customer services: +44 870 010 8002 (national rate).

For other, please visit Support section. You may also send mail to the following
postal address:

27 Great West Road

Brentford

Middlesex

TW8 9BW

United Kingdom

If you have comments on SEGA's online activities or ideas on how to improve them,
please email info@segahelp.com. Please note that by doing so, you also grant SEGA
permission to use and incorporate your ideas or comments without further
compensation.