Updated October 08, 2025

Our Privacy Commitment

Our Privacy Notice describes the kinds of personal information (or “personal data”) we collect, why we collect it, how we disclose it, and the choices we give you when you access or use the Pokémon network of websites (for example, Pokemon.com and PokemonCenter.com), as well as apps, features, services, events, and communications provided by Pokémon where this Privacy Notice is posted (collectively, the “Services”).

We also recognize the need to provide additional protections for kids who visit and/or use our Services. To learn about privacy protections for kids, read Pokémon's Supplemental Kids' Privacy Notice.

Pokémon is a valid licensee, and participating member in good standing, of the Children's Advertising Review Unit's (“CARU”) COPPA Safe Harbor Program (“CARU Safe Harbor”). CARU conducts independent audits of our Services and uses other enforcement and accountability mechanisms in its certification process. Services bearing the CARU Safe Harbor icon meet established online information collection, use, and disclosure practices in compliance with applicable privacy laws and best practices.

DISCLAIMER: Although CARU does not monitor non-U.S. based Services or PokemonCenter.com, Pokémon takes steps to confirm that non-U.S. based Services and PokemonCenter.com follow the applicable data collection guidance and principles of CARU Safe Harbor, including adherence to regulations in the European Union (“EU”) and other territories outside of the United States (“U.S.”).

TABLE OF CONTENTS

Privacy Notice

1. What does this Privacy Notice cover?

2. What personal information is collected about you?

3. How is your personal information used?

4. How is your personal information disclosed?

5. How long do we keep your personal information?

6. What choices do you have about processing your personal information?

7. What steps do we take to safeguard your personal information?

8. Specific data processing details

9. Information for individuals

10. International data transfers

11. CARU's COPPA Safe Harbor Program

12. Notice to California Residents

13. How will you know if we amend this Privacy Notice?

14. How to contact us about your personal information and this Privacy Notice

Supplemental Kids' Privacy Notice

1. What types of information do we collect about kids?

2. How do we use and disclose the personal information that we collect from kids?

3. How do we notify and obtain consent from parents for the collection of personal information from their kids?

4. How can parents access, change, or delete personal information about their kids?

5. How will we notify parents if our Kids' Privacy Notice changes?

6. CARU's COPPA Safe Harbor Program

1. What does this Privacy Notice cover?

Our Privacy Notice applies to the collection and processing of personal information by The Pokémon Company International, Inc. (“TPCi”) and our subsidiaries and affiliated companies acting on our behalf (collectively “Pokémon” or “we”, “us”, or “our”). This Privacy Notice does not apply to human resources data or the “Pokémon Careers” website.

Our international affiliates and third-party websites or apps that our Services link to, or with whom we may have a presence, or with whom we may license use of our trademarks and copyrights, may collect and use personal information for their own purposes. Where they do so, their respective privacy notices apply. Please review the respective terms and privacy notices of these entities to learn how they process your personal information. For example, Pokémon GO is developed and distributed by Niantic, Inc. Please visit https://nianticlabs.com/privacy/pokemongo/en/ for information about how Niantic, Inc. processes your data.

In certain territories only, e‑commerce transactions on PokemonCenter.com are operated by Global-e US Inc or Globale U.K. Limited (“Global-e”) acting as our appointed merchant of record. The checkout is provided within our site and operated by Global-e. In those cases, your agreement is concluded with Global‑e (acting in its own name and on its own account), which is responsible for accepting and fulfilling your order, processing payment, arranging delivery, and handling any warranty claims. Pokémon acts only as an intermediary in the conclusion of your purchase agreement with Global-e and are not party to any concluded agreement between you and Global-e regarding any purchased item. The Pokémon Company International, Inc. and Global‑e each act as independent controllers of any personal information processed for their respective purposes related to that purchase. Please refer to Global‑e’s own terms of use and privacy notice for information about its processing of your personal data available under https://www.global-e.com/consumer-privacy-policy//, and see the product‑specific details under Section 8 below for how we process your personal information in this context. Currently Pokémon Center transactions in Australia, New Zealand, and Germany are operated by Global-e in this manner.

2. What personal information is collected about you?

Information you provide to us

We collect personal information directly from you, such as when you, create an account, make a purchase, fill out a form, complete a survey, submit or post content through our Services, communicate with us via third-party platforms, participate in the Play! Pokémon program, participate in a contest, sweepstakes, or promotion, sign up for marketing communications from us, request customer support, or otherwise communicate with us. The types of personal information we collect directly from you include, for example:

• Contact information and identifiers: such as your first and last name, email address, telephone number, postal address, driver’s license or state identification card number, and non-Pokémon and Pokémon account IDs.

• Content and files: data and content you share or upload, such as photos (including any metadata included in your photos and content).

• Payment information: we work with a third-party payment processor to process your payment information, such as credit card numbers or financial account information if you purchase a product or service from us or claim a Play! Pokémon scholarship.

• Demographic information: information you provide when you sign up for a Pokémon Trainer Central Account or the Play! Pokémon program, or when you fill out a survey, such  as your age and/or date of birth, gender, country/region of residence, hobbies, and preferences.

• Location data: In certain Services, we may collect broad location information such as state and city or your address.

Information we collect automatically

We automatically collect certain information when you use our Services. For example:

• Identifiers and device information: such as your device type, operating system type, browser type, device ID, Internet Protocol (IP) address, and other software including type, version, language, settings, and configuration.

• Information collected by cookies and similar tracking technologies: We store and retrieve data using cookies and similar technologies, such as pixels to collect information about your interactions with the Services and our marketing communications. These technologies help us improve our Services and marketing communications, personalize your experience, and analyze your interactions with us. In addition, when you visit Pokémon Center, we use additional types of cookies and tracking technologies to show you ads that are targeted to your interests and better understand your interactions with us. For example, we collect information about your browsing behavior, such as pages viewed, links clicked, information about your activity on a specific page, items placed in your cart or added to your wish list. Furthermore, when you complete a purchase via Global-e, additional cookies and tracking technologies (set by us and/or by Global-e) are used to operate the checkout and complete your order. For more information about the cookies and tracking technologies we use and the choices available to you, see our COOKIE PAGE.

• Usage data: such as what website you were on that brought you to our website, when you used our Services and for how long, what pages and content you accessed, and features you used on our Services.

• Location data: In certain Services, we may collect broad location information, for example, as derived from your IP address.

• Customer support center communications: In the United States, calls to our customer support centers may be monitored and retained, including for quality assurance and training purposes. You will be informed before being connected. Text and chat with customer support may also be monitored and retained for quality assurance and training purposes.

• Security camera footage: Our automated retail devices (also known as vending machines) are equipped with camera equipment that may record video footage to protect against unauthorized access.

• Transaction information when you make a purchase: If you make a purchase on our Services or at a vending machine, we collect information about your transaction, including product details, purchase price, and date of the transaction.

Information we create or generate

We may derive other information from data we collect about you, and we may combine this with other personal information to generate information about your likely preferences or other characteristics (“inferences”). For example, we infer your general location from your IP address.

Information we obtain from other sources

We obtain information from other sources including:

• Non-Pokémon account operators: please see Play! Pokémon section below;

• Mobile Platforms: when you download our apps and/or make an in-app purchase, we receive information from the app stores and other mobile platform providers about you that is limited to username or screen name and/or device ID and the fact that a purchase was made, unless you authorize the mobile platform providers to provide us additional information;

• Merchant of record partner: in connection with purchases completed via Global-e, we receive order and customer details as described in the PokemonCenter.com section (for example, order details, information necessary for API requests, and order status updates).

• Service Providers: service providers may collect any of the categories of personal information described above to provide services on our behalf, including to help us determine your device's general location based on its IP address to customize certain products to your location, provide you a more convenient experience, and provide additional security measures to protect our Services; and

• Social Networks: where the information, including your name, screen name, and content you post, is publicly available to us, we may use such data for purposes  such as gauging public opinion regarding the Services and Pokémon.

Cookies and Tracking

Our websites use a variety of technical methods for collecting and tracking device information and usage data, including web beacons, cookies, local storage, and device IDs. Please see our COOKIE PAGE for more information on how we use cookies and similar technical methods, and how you may exercise your choices over cookies.

Individualized Links and Tags

We may use individualized links and tags to track the performance of links from our websites and email. Individualized links and tags are snippets of text attached to a URL that help Pokémon identify where website traffic comes from and track the performance of marketing activities.

reCAPTCHA

Our websites may implement Google's reCAPTCHA Enterprise to prevent malicious activity. Information is collected by Google to determine whether the visitor is a human being or a bot, as well as for general security purposes. You can read which information is collected by Google and what the information is used for at https://policies.google.com/privacy. You can read the Terms of Use for Google services and products at https://policies.google.com/terms.

3. How is your personal information used?

We use your personal information to the extent necessary to: perform our contract with you (or to take steps at your request prior to entering into a contract with you), based on consent where we have requested it, where required by law, or for our legitimate business objectives.  We describe this in more detail below:

Additional Information for Residents of Mexico:

Since the secondary purposes do not give rise to, or are not necessary for a legal relationship between Pokémon and the data subjects, in the event that You do not want your personal information to be processed for these secondary purposes, please send an email to the following email address privacyquestions@pokemon.com, indicating your refusal to permit the use of your personal information for the above-listed secondary purpose or purposes.

4. How is your personal information disclosed?

We disclose personal information as follows:

With subsidiaries and affiliates to provide you with the Services and take actions based on your request, as well as for the purpose of management and analysis

• With vendors, consultants, and other service providers who work for us and need to access your personal information to do that work, including 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).

• Categories of vendors we disclose personal information to: other game developers, game and app platforms, customer support vendors, social media platforms, authentication providers, cloud storage and IT service providers, payment processors, event registration providers, warehousing, packing, shipping and delivery partners, retail partners, survey, questionnaire, and product review operators, sweepstakes and contest providers.

• With Global-e, our e-commerce merchant of record for certain PokemonCenter.com purchases. We and Global-e disclose personal information to each other as independent controllers to enable you to conclude and fulfil your purchase agreement with Global-e, as described in the PokemonCenter.com product-specific Section 8.

• With your consent; for example, when you agree to our sharing your information with other third parties for their own purposes, subject to their separate privacy policies

• If you've selected options available through our Services to publicly display your name and/or screen name and your other information

• If appropriate to (a) comply with laws or to respond to lawful requests and legal processes, including, for example, to comply with a court order or subpoena; (b) protect the rights and property of Pokémon, our agents, our customers, and others, including to enforce our terms, policies, rules, and agreements; (c) protect the safety and security of any person; and/or (d) protect the safety and security of Pokémon's and our partners' Services, websites, and applications

• 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 for use in accordance with applicable law

We also disclose aggregated or de-identified information that cannot reasonably be used to identify you. We maintain and use this information only in a de-identified fashion and will not attempt to re-identify such information, except as permitted by law.

Additional Information for Residents of Mexico:

We inform You that to carry out the transfers of your personal data referred to in Section 4, obtaining your consent is not required since those transfers are covered by the exceptions established under Mexican law, excluding the following:

1. Third parties for their own purposes, subject to their separate privacy policies.

2. If you've selected options available through our Services to publicly display your name and/or screen name and your other information.

3. 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 for use in accordance with applicable law.

In the event that you do not want your personal data to be communicated for one or more of the transfers listed in this section, please send a message to the following email address privacyquestions@pokemon.com, indicating your refusal to allow the use of your personal data for the transfers of your choice.

5. How long do we keep your personal information?

Pokémon keeps your personal information for as long as appropriate to maintain your accounts, to provide Services, to fulfill your requests, 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.

6. What choices do you have about processing your personal information?

We provide you with various controls over your personal information, for example:

• You can access and update the contact information you gave us during registration by visiting the “Edit Profile” section on www.pokemon.com or the “My Account” section on www.pokemoncenter.com.

• You can opt out of receiving text messages or promotional emails from us by following the instructions in those communications. You can also prevent tracking of emails we send you by changing your settings to turn off HTML or disable downloading of images.

• You can manage your cookie settings and choose to block and/or remove all cookies and local storage by navigating to our privacy preference center. You can access the privacy preference center by clicking “Manage Cookies” when you first navigate to our webpage, and can change your settings at any time by clicking the “Manage Cookies” button on our Cookie Page. For information on how to do this, please visit our COOKIE PAGE. Please note that cookies are managed separately on Pokemon.com and Pokemoncenter.com.

• You can also opt out of many of the third-party analytics and advertising cookies as described in the COOKIE PAGE by visiting http://www.aboutads.info/choices/ and http://www.networkadvertising.org/choices/.

• You can enable the Global Privacy Control (GPC) on your browser to communicate your privacy preferences. If Pokémon detects your GPC signal, Pokémon will turn off all cookies except strictly necessary cookies. You will need to turn this on for each browser you use.

You may also have certain privacy rights based on the jurisdiction in which you reside. For more information, please see Section 9, “Information for Individuals”, below.

7. What steps do we take to safeguard your personal information?

We implement technical, organizational, administrative, and physical security measures designed to protect your personal information from unauthorized access and improper use. However, please understand that despite our best efforts, no security measure is perfect or impenetrable.

8. Specific data processing details

The following are product-specific details to supplement the information in this Privacy Notice.

Play! Pokémon

If you participate in the Play! Pokémon program, we will use personal information about you to track your tournament results, player ranking, rating, and player status (e.g., active, terminated, winner, etc.). Except for those jurisdictions where privacy law specifies a different age, (a) if you are 13 or older, we will post your full name,  first name and last initial, screen name, or anonymously assigned username (as you direct us), as well as your state and country/region with your player ranking; and (b) if you are under 13, your parent or guardian can choose to post your screen name, full name, or first name and last initial, or anonymously assigned username in the player rankings. If you choose not to create a Pokémon Trainer Central account after participating in Play! Pokémon events, we will retain your first name, first initial of last name, date of birth, and any Championship Points earned for participating in any event where this information alone cannot identify you and is not considered personal information.

Also, if you participate in the Play! Pokémon program, we may disclose your personal information to independent third parties (such as League Leaders, League Assistants, and Tournament Organizers) who run Play! Pokémon events that you may participate in. In most cases, these are independent third parties and not Pokémon employees.

If you've signed up to play our products or participate in competitions and provide us with non-Pokémon account information (e.g., a Nintendo Account) where that function is available, we will receive your date of birth and account ID from the other account operator. If you are participating in competitions to be awarded Play! Pokémon Championship Points, the date of birth from your non-Pokémon account will be verified against your Pokémon Trainer Central (“PTC”) Account, and information about whether there was a match or not, and your PTC ID will be disclosed to the other account operator.

If you apply to become a Professor in the Play! program, we may direct you to undergo a background check. The background check provider will have its own terms regarding personal information, which will be provided to you during the application process.

Pokémon Apps

Pokémon will keep your personal information within a Pokémon app for as long as you keep the app on your device. If you create an account, the app sends your personal information to our servers. We keep your data for as long as you maintain an account and for 90 days after you disable the account, in case you choose to reactivate the account or in case the request to disable the account was in error. Certain apps may give you the option to receive push notifications. You can turn push notifications on or off through settings within the app or your device.

PokemonCenter.com

If you provide information to create an account or as part of a transaction, payment, or other account action, Pokémon may deliver marketing communications to you about similar goods or services if you have not opted out of such marketing when given the chance to do so.

For certain countries, when you buy items offered on PokemonCenter.com, these purchases will be operated by Global-e. In those cases, your purchase agreement is concluded with Global‑e, acting in its own name and on its own account even if the checkout is provided within our site. Global‑e accepts and processes your order, arranges delivery, and handles customer service and warranty claims, while we act only as an intermediary for that purchase. The Pokémon Company International, Inc. and Global‑e act as independent controllers for their respective processing and have a data sharing agreement in place. To enable checkout and fulfilment, we share product catalogue, pricing, product details, cart contents and, if you complete the purchase using a registered Pokémon account, your billing address and phone number with Global‑e; Global‑e shares with us certain purchase information (final order details), technical data necessary for API requests between our systems, order status updates, and basic customer details required for the order via Fluent Commerce (e.g. name, billing address and, where necessary, telephone number). Any personal information shared by Global-e with us is limited to the extent necessary to fulfill your purchase agreement and our contractual obligations with Global-e. Any processing of your personal information by Global‑e, including the purpose of fraud detection, is governed by their own terms and privacy notice. Please review their privacy notice available under https://www.global-e.com/consumer-privacy-policy// to understand how they use your information. Currently Pokémon Center transactions in Australia, New Zealand, and Germany are operated by Global-e in this manner.

Where purchases are not completed via Global-e, we may also use other third parties, such as Authorize.net and PayPal, to process payment transactions and facilitate fraud protection. PayPal and other third-party entities may use your information for their own purposes, including to service accounts you have with them and for fraud prevention. We may use authorized resellers in some countries to process your transactions. Please review their respective privacy notices to understand how they use your information. PokemonCenter.com's services are intended for customers in the United Kingdom, United States, Canada, Australia, New Zealand, and Germany. For more information, please refer to the PokemonCenter.com Terms of Use.

Automated Retail Devices (a.k.a. Vending Machines)

Pokémon operates automated retail devices (also known as vending machines) in certain locations in the United States. If you make a purchase from one of these devices, the device will collect payment card and other payment information for the purpose of processing and completing your purchase. The device will also provide you with the option to input your email address or phone number for the purpose of sending purchase receipts. Receipts will be sent by VendNovation LLC, a partner that assists Pokémon in operating the devices, on Pokémon 's behalf, and, if you select email address, it may include links to other Pokémon product and services that are governed by other sections of this Privacy Notice. Message & Data rates may apply. Pokémon 's automated retail devices are equipped with camera equipment that counts the number of  people passing in front of the device as well as camera equipment inside the machine that records when individuals retrieve their item from the machine to protect against unauthorized access.

Market Research

We sometimes send surveys to our customer base or other consumers to gather market information and improve our products and services. While we do not ask for personal information in your survey responses, in certain instances your survey responses may be connected to automatically collected information such as a cookie ID. We only use the automatically collected information for troubleshooting purposes in the event that we identify any technical issues and to prevent requesting repeat surveys. Some surveys may have open text fields requesting your general feedback. We caution you not to submit identifying information within these fields.

We may also hire market research companies that will have their own terms and privacy practices regarding personal information.

Influencers

If we engage you as an influencer for one or more of our marketing campaigns, we may collect your name, social media handle(s), shipping address and payment information in connection with the engagement. We use this personal information to fulfill our contract with you. We may also need to collect and maintain personal information to fulfill our legal obligations.

9. Information for individuals

You may have the following rights (“data subject rights”) depending on the jurisdiction in which you reside:

• A right to be informed of the ways in which we use your information;

• A right to be informed about the entities to which your personal information has been disclosed;

• A right to confirm whether your personal information is being processed at any time;

• A right to request from Pokémon access to personal information, including (i) the categories and specific pieces of information we have collected about you, (ii) the categories of sources collected, (iii) the purpose for collecting or using the information, and (iv) the third parties to whom we disclose your personal information;

• A right to request rectification/correction of your personal information;

• A right to request deletion/erasure/anonymization of your personal information under certain circumstances and subject to a number of exceptions;

• A right to access the contractual provisions that regulated international data transfers, as applicable;

• A right to object to the processing of your personal information or obtain a restriction of such processing under certain circumstances;

• A right to receive personal information we hold about you in a structured, commonly used, and machine-readable format under certain circumstance, or have your personal information transferred to another organization should it be technically feasible for Pokémon to do so;

• If the processing of personal information is based on your consent, a right to withdraw consent at any time (without affecting the lawfulness of processing before its withdrawal);

• In certain contexts, the right to limit the use and disclosure of your personal information;

• We do not use solely algorithmic or other automated decision-making that produces legal or otherwise significant effects; however, you have a right to object to such automated decision-making;

• The right to appeal our decision regarding your request to exercise your data subject rights; and

• A right to bring your complaint to a regulator. If you are based in the European Economic Area (EEA) and believe that we have not complied with data protection laws, you can complain to our regulator, the UK Information Commissioner's Office, the Ireland Data Protection Commission, or your local supervisory authority; however, regardless of where you are based, we would appreciate it if you would give Pokémon the chance to deal with your concerns directly by contacting us.

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.

To make such requests, contact us at privacyquestions@pokemon.com or https://support.pokemon.com/hc/requests/new?ticket_form_id=360000012406. If you are based in the EEA, you may also contact us at EU-privacy@pokemon.com.

If you submit a request, we will require you to verify your identity either by making the request through your existing account and/or by providing a form of governmental identification through our customer service portal, 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.

10. International data transfers

Pokémon's business operates on a global scale. When you access or submit information to us, your personal information may be transferred to, processed, maintained, and used on computers, servers and systems located where the data protection laws may not be as protective as those in your jurisdiction. If you choose to provide personal information to us in connection with your use of the Services, please note that we may transfer your personal information to servers located in the United States of America, the United Kingdom, and other countries or regions that may not have the same types of data protection laws as those in your country. We will take appropriate contractual or other steps to protect the relevant personal information in accordance with applicable laws. Where purchases are completed via Global-e, related inter-controller disclosures between Global-e and us and any resulting international transfers occur subject to the safeguards described in this section.

Whenever we transfer your personal information from inside the EEA, Switzerland, Brazil, or the United Kingdom to other countries or regions, the transfer will be based on at least one of the following:

(a) Standard Contractual Clauses approved by the appropriate data protection authority (e.g. European Commission or the Brazilian National Data Protection Authority (ANPD)), and the UK International Data Transfer Addendum issued by the Information Commissioner's Office as providing an adequate level of data protection.

(b) Transfer to a country, territory, or specified sector within a country or territory that the European Commission or ANPD has determined to ensure an adequate level of protection of personal information.

(c) 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, or other legal methods available to us under applicable law.

This may include a requirement for Pokémon to release personal information in response to a legal obligation or legal process. Such obligations may include lawful requests by public authorities, including to meet national security and law enforcement requirements. When we disclose your personal information to comply with a legal obligation or legal process, we will take reasonable steps to ensure that we disclose only the minimum personal information necessary for the specific purpose and circumstances to comply with legal obligations or valid legal processes such as search warrants, subpoenas, or court orders. When we do, transfer your personal information we use a variety of legal mechanisms, including contracts and standard contractual clauses / model clauses, so that your rights and protections travel with your data.

We participate in the EU-U.S. Data Privacy Framework program (EU-U.S. DPF), the UK Extension to the EU-U.S. DPF, and the Swiss-U.S. Data Privacy Framework program (Swiss-U.S. DPF) as set forth by the U.S. Department of Commerce. We have certified to the U.S. Department of Commerce that it adheres to the EU-U.S. Data Privacy Framework Principles (EU-U.S. DPF Principles) with regard to the processing of personal information received from the European Union in reliance on the EU-U.S. DPF and from the United Kingdom (and Gibraltar) in reliance on the UK Extension to the EU-U.S. DPF. We have certified to the U.S. Department of Commerce that it adheres to the Swiss-U.S. Data Privacy Framework program Principles (Swiss-U.S. DPF Principles) with regard to the processing of personal information received from Switzerland in reliance on the Swiss-U.S. DPF. If there is any conflict between the terms in this privacy policy and the EU-U.S. DPF Principles and/or the Swiss-U.S. DPF Principles, the Principles shall govern. To learn more about the Data Privacy Framework (DPF) program, and to view our certification, please visit https://www.dataprivacyframework.gov/. TPCi is subject to the investigatory and enforcement powers of the Federal Trade Commission (FTC) in regard to personal information transferred under the DPF. TPCi is also responsible for personal information transferred under the E.U-U.S, Swiss-U.S Data Privacy Framework and the U.K Extension that TPCi then transfers to third party agents. TPCi remains liable for processing by such third parties that is not consistent with the DPF (absent proof of causation by events not attributable to TPCi).

In compliance with the EU-U.S. DPF Principles, we commit to resolve complaints about your privacy and our collection or use of your personal information transferred to the United States pursuant to the DPF Principles. European Union, Swiss and United Kingdom individuals with DPF inquiries or complaints should first contact us at privacyquestions@pokemon.com, or by certified mail (return receipt requested) at The Pokémon Company International, Inc., Attention Privacy Notice Administrator, 10400 NE 4th Street, Suite 2800, Bellevue, WA 98004 USA. For any complaints that cannot be resolved with us directly, you may refer the matter to BBB Data Privacy Framework Services, operated by BBB National Programs, Inc. Visit https://bbbprograms.org/programs/all-programs/dpf-consumers/ProcessForConsumers for more information and to file a complaint with BBB Data Privacy Framework Services. This service is provided free of charge to you. If your complaint remains unresolved after contacting Pokémon, and the BBB Data Privacy Framework Services, you also have a right to lodge a complaint with a supervisory authority.

If your DPF complaint cannot be resolved through the above channels, under certain conditions, you may invoke binding arbitration for some residual claims not resolved by other redress mechanisms. See https://www.dataprivacyframework.gov/s/article/G-Arbitration-Procedures-dpf?tabset-35584=2

The data collected is only transferred to countries that provide a degree of protection similar to or greater than what was provided by the exporter, or to companies that contractually undertake to adopt a degree of protection similar to that provided for in the applicable legislation.

11. CARU's COPPA Safe Harbor Program

Pokémon is a licensee of CARU's COPPA Safe Harbor Program. If you believe that we have not responded to your privacy-related inquiry or your inquiry has not been satisfactorily addressed, please contact CARU online at https://bbbprograms.org/programs/caru; by mail at CARU, Attn.: COPPA Safe Harbor Program, 112 Madison Avenue, New York, NY 10016 USA; or by email at infocaru@bbbnp.org.

Please note that CARU is not affiliated with Pokémon and cannot help you with non-privacy-related issues.

12. Notice to 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 the Services (“customer”), the California Consumer Privacy Act (“CCPA”) provides you with certain rights including those described in Section 9 together with the rights and disclosures set forth below. You have a right not to be discriminated against for exercising any of these rights.

Pokémon does not share your personal information for cross-context behavioral advertising, or sell it (as those terms are defined under California law), and has not done so in the past 12 months.

If you have authorized an agent to submit a request to know or a request to delete, Pokémon may require that you (i) provide written permission for a named agent to do so; (ii) verify your identity directly with Pokémon; or (iii) provide the authorized agent with a valid power of attorney. Pokémon may deny a request made on your behalf if the agent does not submit proof authorizing such request.

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 at the email address or postal address listed above.

If you are a California resident under the age of 18, and a registered user of any Service where this privacy notice is posted, you may request and obtain removal of content or information you have publicly posted. To make such a request, please send an email with a detailed description of the specific content or information to privacyquestions@pokemon.com. Please be aware that such a request does not ensure complete or comprehensive removal of the content or information you have posted, and that there may be circumstances in which the law does not require or allow removal even if requested.

In the past 12 months, we have collected the following categories of personal information, as described in the CCPA:

• Identifiers (e.g., contact information);

• Commercial information (e.g., purchase history and details);

• Internet activity information (e.g., usage data);

• Demographic information (e.g., date of birth);

• Geolocation data (e.g., your current location derived from your IP address);

• Audio and visual information (e.g., customer support center calls);

• Other “personal information” as defined under California law; and

• Inferences drawn from any of these categories.

For details about the data we collect and the categories of sources from whom we collect, please see Section 2 “What personal information is collected about you?” We collect personal information for the business and commercial purposes described in Section 3 “How is your personal information used?”. For details about the categories of parties with whom your personal information may have been shared for a business purpose, please refer to Section 4 “How is your personal information disclosed?”.

13. How will you know if we amend this Privacy Notice?

We may amend this Privacy Notice at any time by changing the last updated date. If we make material changes, we will provide you with additional notice (such as by adding a statement to the Services or sending you a notification), and, if required by law, we will seek your consent for such changes.

14. How to contact us about your personal information and this Privacy Notice

If you have questions or comments about our data practices or this Privacy Notice, you can contact us or our data protection officer at:

The Pokémon Company International, Inc.
Attn.: Saffet Ozdemir

Data Protection Officer

privacyquestions@pokemon.com

Residents of the UK and EEA may also contact us at EU-privacy@pokemon.com.

Additional Information for Residents of Mexico:

The address of the controller in Mexico is located at:

Av. Emilio Castelar 75, Piso 9, Polanco IV Sección, Miguel Hidalgo

C.P. 11550, Ciudad de México, México

Additional Information for Residents of Brazil:

Brazil residents may contact us at privacyquestions@pokemon.com.

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Supplemental Kids' Privacy Notice

OUR ADDITIONAL PRIVACY COMMITMENT TO KIDS AND THEIR PARENTS

Pokémon has developed its Services with the goal of creating an enjoyable experience for all users. Building on our general Privacy Notice, we recognize the need to provide additional privacy protections when kids visit the Services on which this Kids' Privacy Notice is posted. This Kids' Privacy Notice is designed to answer your questions regarding our privacy policies and principles with respect to kids. As used in this Notice, “children”, “child”, and “kid(s)” refer to children under the age of 13, except for those jurisdictions where the privacy law specifies a different age. Also, when we use the term “parent”, we include legal guardians.

Please note that this Supplemental Kids' Privacy Notice does not apply to PokemonCenter.com.

1. What types of information do we collect about kids?

Our guests can use some of our Services, view content, and enjoy many features without registering for an account or our collection of any personal information subject to COPPA.

If a user has indicated that they are a kid when trying to create a Pokémon account, we will collect a parent's email address and obtain verifiable parental consent before allowing the kid to provide any additional personal information. See below to learn how we seek parental consent.

Once we obtain parental consent, a kid can use our services much like any other user. And we may collect from the kid the same types of personal information, and use and disclose that information for the same purposes, as described in the general Privacy Notice with the exception that Pokémon does not, nor does it allow third parties to, collect kids' personal information (including persistent identifiers) for targeted advertising, amassing a profile, or any purpose other than to support its internal operations unless we have obtained explicit prior parental consent.

We receive information from our guests directly and from third parties such as Play! Pokémon Tournament Organizers. We collect personal information from parents on behalf of their kids to create an account for Pokémon's Services.

Pokémon does not condition participation in any of its Services for kids on the collection of more personal information than is reasonably necessary.

2. How do we use and disclose the personal information that we collect from kids?

As noted above, once we obtain parental consent, a kid can use our Services much like any other user. And we may collect from the kid the same types of personal information, and use and disclose that information for the same purposes, as described in the general Privacy Notice, unless otherwise specified in this Supplemental Kids' Privacy Notice. For example, once a parent has provided consent to create an account, a kid can:

• Link an account from one of Pokémon's Services with an account from another Service operated by Pokémon or an affiliate of Pokémon

• Participate in games, reward programs, contests, sweepstakes, events, or promotions

• Send us questions or correspond with us via email or our customer support portal concerning the Services or the kid's participation in organized events

• Participate in polls, surveys, or questionnaires

• Use our preloaded response features and participate in “canned chat” in our apps, where a kid can select catchphrases from a list prepared by Pokémon to be displayed to their opponent before and after battles, as well as send emoticons to other users during battle.

• Enable push notifications (you can turn push notification on or off by modifying the settings within the applicable Service, or within your device's settings)

Note that some Services may enable a kid to publicly disclose personal information and/or communicate with other users. We do not have control over third parties (e.g., other users) who may have copied or reposted publicly posted information.

Until we receive verifiable parental consent, the parent's contact information gathered from a kid is used only to obtain the parent's consent for our information collection practices.

With parental consent, we may also use a kid's contact information to send the kid emails and messages with promotional information about new products and features, special offers, contests, and sweepstakes, as well as other interesting information concerning new products, events, and updates about Pokémon. Parents can always choose whether their kid may receive these promotional messages by visiting their account profile settings or contacting us.

If a kid wins a prize from a sweepstakes, contest, or other promotional event, we will notify the parent at the parent's email address and request that the parent provide their postal address for the purpose of delivering the prize. With the appropriate consent, we may publish a winner's first name, city, state of residence, and country/region.

Pokémon discloses kids' personal information to the same entities and for the same purposes described in the general Privacy Notice.

Also, if a parent chooses to allow a kid to participate in the Play! Pokémon tournament ratings and rankings portion of our websites, we will use personal information about the kid to track the kid's tournament results, player ranking, rating, player status (e.g., active, terminated, winner, etc.). A parent can choose to post a kid's screen name, full name, or first name and last initial in the player rankings. We will also disclose the kid's personal information to independent third parties (such as League Leaders and Tournament Organizers) so they can run offline Play! Pokémon events that the kid may participate in. If a parent doesn't want their kid's personal information disclosed to independent third parties who run Play! Pokémon events, then they should not allow their kid to participate in the Play! Pokémon tournament ratings and rankings portion of our websites.

We do not “share” kids' personal information for cross-context behavioral advertising, or “sell” it (as those terms are defined under California law).

3. How do we notify and obtain consent from parents for the collection of personal information from their kids?

When a kid seeks to register with our Services, we will email their parent. This email notifies the parent that their kid wishes to register, and it asks the parent to create an account to grant consent for their kid to register. If the parent ignores or refuses to register their kid, we will delete the kid and parent's contact information within 14 days of such notice. If the parent permits the registration, we will grant the kid access to the features described in the email and this Privacy Notice.

To help verify that the parent is the person providing consent, Pokémon (in the US in conjunction with Veratad, a leading age and identity verification company) asks for the sum of the first and last digit of the parent's Social Security number, as well as other pieces of information to verify the parent's identity, such as name, birth date, and physical address. Note that Pokémon does NOT store this information anywhere in our records.

Parents can revoke consent at any time by contacting our customer service department and submitting a request on the https://support.pokemon.com/hc/requests/new?ticket_form_id=360000012406 website or emailing privacyquestions@pokemon.com.

4. How can parents access, change, or delete personal information about their kids?

At any time, a parent can log into their Pokémon Trainer Central account to access their “Edit Profile” section or contact our customer service department to access or change the personal information in their kid's account.

A parent may delete the personal information that we have collected from their kid by submitting a request on the https://support.pokemon.com/hc/requests/new?ticket_form_id=360000012406 website or emailing privacyquestions@pokemon.com. The parent should include their kid's username and the parent's email address in the email so that we can better assist with the inquiry or request.

5. How will we notify parents if our Kids' Privacy Notice changes?

We may amend our Kids' Privacy Notice at any time; when we do so, we will change the last updated date. We will notify parents of any material changes in the way we intend to process kids' personal information. We will apply material changes to our Kids' Privacy Notice only when the changes are in compliance with applicable law, including any parental consent requirements.

6. CARU's COPPA Safe Harbor Program

Pokémon is a licensee of CARU's COPPA Safe Harbor Program. If you believe that we have not responded to your privacy-related inquiry or your inquiry has not been satisfactorily addressed, please contact CARU online at https://bbbprograms.org/programs/caru; by mail at CARU, Attn.: COPPA Safe Harbor Program, 112 Madison Avenue, New York, NY 10016 USA; or by email at infocaru@bbbnp.org.

Please note that CARU is not affiliated with Pokémon and cannot help you with non-privacy-related issues.

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