Effective January 1, 2020
Our Privacy Commitment
Pokémon respects your privacy rights and recognizes the importance of protecting your personal information (or “personal data”). Our Privacy Notice describes the kinds of personal information we collect, why we collect it, how we share it, and choices we give you.
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 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.”).
Our Privacy Notice applies to the collection and processing of personal information by The Pokémon Company International, Inc. and our subsidiaries and affiliated companies acting on our behalf (collectively “Pokémon” or “we”, “us”, or “our”). This Privacy Notice applies only to personal information collected about you as a consumer through 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 (“Services”). This 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.
We don't require personal information to use many of our Services. If you choose not to disclose personal information, however, you will not be able to enjoy certain features of our Services.
Information you provide to us
The types of personal information we collect directly from you include, for example:
Contact information: such as your first and last name, email address, telephone number, postal address, and non-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: for example, 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 about you tied to your personal information, such as your age and/or date of birth, gender, country/region of residence, hobbies, and toy and game preferences.
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. Our website and online services store and retrieve data using cookies set on your device, as further described in 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.
Geolocation data: with your consent, the Services may access precise geolocation data on your mobile device to enable features and deliver content based on your current location.
Information we create or generate
We derive other information from the other 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 third-party sources
In limited circumstances, we also obtain information from third parties. We protect information obtained from third parties according to the practices described in this statement, plus any additional restrictions imposed by the source of the information. These third-party sources include, for example:
Non-Pokémon account operators: please see Play! Pokémon section below;
Mobile Platforms: when you purchase our apps, we receive information from the app stores and other mobile platform providers about you that is limited to username and/or device ID and the fact a purchase was made, but no other sensitive or financial information, unless you authorize the mobile platform providers to provide us additional information;
Service Providers: third parties 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, user name, and content you post, is publicly available to us, we may use such data for purposes such as measuring public reaction to the Services and to Pokémon.
Cookies and Tracking
We use your personal information to the extent reasonably necessary to fulfill your requests in performing our contract with you, or based on consent where we have requested it or where required by law, and for our legitimate business objectives, including for the following business purposes:
Business Operations: to provide you with and operate, maintain, optimize, and improve our products, services, operations, and the security of our Services, including to perform operational tasks such as billing, accounting, communicating, and fulfilling your transactions for products and services.
Product and Service Delivery: to personalize content and experiences on our Services, including providing you recommendations based on your preferences;
Marketing: to deliver and personalize your notifications, communications, newsletters, advertisements, offers, event notices, and promotions for products and services of Pokémon and our third-party partners;
Product Improvement, Development, and Research: to develop information to understand you based on demographics, your activity on our Services, responses to surveys, or activity on third-party websites and applications, including for purposes of troubleshooting and improving our Services; to conduct market research and perform statistical, demographic, and marketing analyses of users of our Services and their purchasing patterns;
Communications: to send and display administrative communications about Pokémon and our partners and our respective products and services;
Security of Services: to detect, investigate, and prevent activities that are unauthorized, may violate our terms and policies, or may be illegal, such as fraudulent activity or security violations; and
Customer Support: to provide customer support and respond to your questions submitted to us.
With the exception of payment information, which is used solely for accounting, billing, order fulfillment, and fraud prevention purposes, all of the categories of information described in Section 2 are used for each of the purposes described above.
For the purposes listed above, we may also link or combine information about you with other personal information we receive from third parties. We also use personal information in settings and for the purposes described below.
We may store and process personal information in the United States, 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 do not share your personal information with third parties other than as follows:
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
With third-party 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). In the past 12 months, we have disclosed to vendors all of the categories of personal information described in Section 2.
If you've selected options available through our Services to publicly display your name and/or username 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
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.
We provide you with various controls over your personal information, for example:
You can contact us at firstname.lastname@example.org with requests to delete, access, and update your personal information.
You can opt out of our promotional emails by clicking “unsubscribe” in those emails.
You can choose to block and/or remove all cookies and local storage. For information on how to do this, please visit our COOKIE PAGE.
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 opt out of our advertising on mobile apps by using the advertising settings in your mobile device.
You can prevent tracking of emails we send you by changing your settings to turn off HTML or disable downloading of images. In addition, you may also unsubscribe from our marketing emails by following the instructions in those emails.
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.
The following are product-specific details to supplement the information in this Privacy Notice.
If you participate in the Play! Pokémon tournament ratings and rankings portion of our websites, 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 or first name and last initial (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 username, full name, or first name and last initial in the player rankings.
Also, if you participate in the Play! Pokémon tournament ratings and rankings portion of our websites, we will share your personal information with independent third parties (such as League Leaders 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 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 Club (“PTC”) Account, and information about whether there was a match or not, and your PTC ID will be shared with the other account operator.
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. You may disable our access to your precise geolocation data through settings in your device.
You have the following rights:
A right to be informed of the ways in which we use your information.
A right to request from Pokémon access to personal data, 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 with whom we share your personal information; and rectification or deletion/erasure of personal information under certain circumstances and subject to a number of exceptions, and certain rights to data portability.
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, 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.
A right to object to the processing of your personal data or obtain a restriction of such processing under certain circumstances.
A right to have your personal data transferred to another organization should it be technically feasible for Pokémon to do so.
If the processing of personal data is based on your consent, a right to withdraw consent at any time (without affecting the lawfulness of processing before its withdrawal)
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 email@example.com or https://support.pokemon.com/hc/requests/new?ticket_form_id=360000012406.
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.
We transfer personal data from the EEA, the United Kingdom, and Switzerland to other countries or regions, some of which have not been determined by the European Commission to have an adequate level of data protection. When we do, 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. Pursuant to the Privacy Shield, Pokémon remains liable for the transfer of personal data to third parties acting as our agents unless we can prove we were not a party to the events giving rise to the damages.
We also comply with the EU-U.S. Privacy Shield Framework and Swiss-U.S. Privacy Shield Framework with respect to the collection, use, and retention of personal information transferred from the European Union, the United Kingdom, and/or Switzerland to the United States. We have certified to the U.S. Department of Commerce that we adhere to the Privacy Shield Principles, and we are subject to the investigatory and enforcement powers of the U.S. Federal Trade Commission. If there is any conflict between the terms in this Privacy Notice and the Privacy Shield Principles, the Privacy Shield Principles shall govern. To learn more about the Privacy Shield program, and to view our certification page, please visit the Privacy Shield List for Pokémon.
In compliance with the EU-U.S. and Swiss-U.S. Privacy Shield Principles, Pokémon commits to resolve complaints about your privacy and our collection or use of your personal information. European Union, United Kingdom, or Swiss individuals with inquiries or complaints regarding this Privacy Notice should first contact us at firstname.lastname@example.org, 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.
Pokémon has further committed to refer unresolved privacy complaints under the Privacy Shield Principles to an independent dispute resolution mechanism, the BBB EU PRIVACY SHIELD, operated by the BBB National Programs, Inc. (“BBBNP”). If we do not appropriately address your complaint, visit http://www.bbb.org/EU-privacy-shield/for-eu-consumers for more information and to file a complaint with the BBBNP. This service is provided free of charge to you. If your complaint is still not resolved, in limited situations, a binding arbitration option may be available before a Privacy Shield Panel.
You also have a right to lodge a complaint with a supervisory authority, but we ask you to first contact us or the BBB with concerns.
Pokémon may be liable for the onward transfer of EU, UK, and Swiss individuals' personal data to third parties that process personal data in a manner inconsistent with the Privacy Shield principles unless Pokémon proves it is not responsible for the event giving rise to the damage.
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.: Data Protection Officer
The Pokémon Company International, Inc.
Attn.: Data Protection Officer
10400 NE 4th Street
3rd Fl Bldg 10, Chiswick Park
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 email@example.com.
Please note that CARU is not affiliated with Pokémon and cannot help you with non-privacy-related issues.
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 sell your personal information as defined by the CCPA 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 firstname.lastname@example.org. 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.
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.
Last updated May 25, 2018
Effective May 1, 2019
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.
TABLE OF CONTENTS
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 share 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 data (including persistent identifiers) for behavioral 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.
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 share 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 Email-a-Friend feature and participate in “canned chat,” where a kid can select words from a list prepared by Pokémon to send messages to other website users
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 shares kids' personal information with 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 username, full name, or first name and last initial in the player rankings. We will also share the kid's personal information with 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 shared with 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.
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 email@example.com.
At any time, a parent can log into their Pokémon Trainer Club 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 firstname.lastname@example.org. 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.
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.
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 email@example.com.
Please note that CARU is not affiliated with Pokémon and cannot help you with non-privacy-related issues.