Privacy Notice

Last updated April 16, 2018

Effective May 25, 2018

Our Privacy Commitment

Pokémon respects your privacy rights and recognizes the importance of protecting your personal information. 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-English Services or PokemonCenter.com, Pokémon takes steps to confirm that non-English 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 (“US”).

  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 shared?

  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. Product-specific data processing details

  9. Information for individuals in the EU and Switzerland

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

  11. CARU's COPPA Safe Harbor Program

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

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. 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.

2. What personal information is collected about you?

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 contact information, such as your first and last name, email address, telephone number, and postal address, as well as content you share or upload, such as photos (including any metadata included in your photos and content) and payment information (for example, credit card numbers or financial account information) if you purchase a product or service from us. We may also collect demographic information tied to your personal information, such as your age and/or date of birth, gender, country of residence, hobbies, and toy and game preferences.

Information we collect automatically

We automatically collect certain information when you use our Services. For example, we may collect device information, such as your device type, operating system type, browser type, device ID, and IP address. We may also collect 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. We may derive other information from the information we collect, such as your general location from your IP address. In addition, 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. We may combine this device and usage information with other personal information.

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.

Cookies are small pieces of text that may be saved on your device when you view our website. We and other companies use unique identifiers in cookies to distinguish your device for a variety of purposes, including helping you navigate our website with ease, remembering your preferences and interests, and tracking your online activities over time and across different websites and online services.

Web beacons are small pieces of data often embedded in images on the pages of our websites and emails. These beacons may request information from our servers or third-party servers to allow download of content and information. Beacons may also be used to set and read cookies. We also use beacons in HTML emails to determine if you open emails or click on links in emails.

Device IDs are unique identifiers for your devices. We and others may collect and use device IDs for tracking activities and usage of our Services, such as how you use our mobile apps.

We may collect and store information (including personal information) locally on your device using local storage mechanisms. Local storage allows data to be stored across web browser sessions. We collect this information for customer support purposes and to send you more relevant marketing.

3. How is your personal information used?

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, and for our legitimate business objectives, including to:

  • Provide you with and operate, maintain, optimize, and improve our products, services, operations, and the security of our Services

  • Personalize content and experiences on our Services, including providing you recommendations based on your preferences

  • Deliver and personalize your notifications, communications, newsletters, advertisements, offers, and promotions for products and services of Pokémon and our third-party partners

  • Develop information to understand you based on demographics, your activity on our Services, or activity on third-party websites and applications

  • Conduct market research and perform statistical, demographic, and marketing analyses of users of our Services and their purchasing patterns

  • Perform operational tasks such as billing, accounting, communicating, and fulfilling your transactions for products and services

  • Send and display administrative and marketing communications about Pokémon and our partners and our respective products and services

  • 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

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 and in other countries that may not have the same types of data protection laws as those in your country.

Third-party cookies used for analytics and advertising

Pokémon uses third parties that may also use their own cookies, web beacons, local storage, device IDs, and other tracking data to assist us with analytics and advertising. Some third parties, including advertisers and ad-related services, may also help us and others associate your activities across your browsers and mobile devices you use for retargeting, advertising, and ad measurement purposes. We and others may also use email tracking technologies to monitor the success of email marketing campaigns (for example, recording how many emails in a campaign were opened).

Please consult the respective privacy policies and statements of these third parties for more information about how they use your data. For examples of privacy notices of third parties who use cookies for tracking, please refer to the chart below:

Third Party Name

Privacy Notice / Opt-Out Choice

Adobe Analytics (Omniture), Typekit by Adobe

http://www.adobe.com/privacy/policy.html

DoubleClick, Google Analytics

http://www.google.com/intl/en/policies/privacy/

New Relic

http://newrelic.com/privacy/

4. How is your personal information shared?

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

  • 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

Your California Privacy Rights

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 below.

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 contact us at privacyquestions@pokemon.com 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. You can do this through your browser (such as Mozilla Firefox or Internet Explorer) settings. If you remove or block cookies and local storage, you won't have access to many features that make your experience smoother and more personalized, and some of our Services may not function properly. Since certain opt-out preferences are also stored in a cookie in your browser (such as opt-outs from advertising companies), please note that if you remove all cookies, you will need to renew your opt-out choices. Some internet browsers may transmit “Do Not Track” signals. Because uniform standards for “Do Not Track” signals have not been adopted, our websites may not be aware of or process “Do Not Track” signals.

  • You can also opt out of many of the third-party analytics and advertising cookies as described in the Privacy Notice in the Third-party cookies used for analytics and advertising section above 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.

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. Product-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 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 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.

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. You may disable our access to your precise geolocation data through settings in 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. We may also use 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. Please review their respective privacy notices to understand how they use your information.

9. Information for individuals in the EU and Switzerland

If you are an individual subject to EU law, 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 and rectification or erasure of personal information, and certain rights to data portability

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

  • 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)

To make such requests, contact us at privacyquestions@pokemon.com.

We transfer personal data from the European Economic Area and Switzerland to other countries, 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, so that your rights and protections travel with your data.

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 and 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 https://www.privacyshield.gov.

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 or Swiss individuals with inquiries or complaints regarding this Privacy Notice 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.

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 Council of Better Business Bureaus (“BBB”). 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 BBB. 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 and Swiss individual's 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.

10. 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
Attn.: Data Protection Officer

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

3rd Fl Bldg 10, Chiswick Park
566 Chiswick High Road
London, W4 5XS
United Kingdom

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 http://asrcreviews.org/asrc-contact-us/; by mail at CARU, Attn.: COPPA Safe Harbor Program, 112 Madison Avenue, New York, NY 10016 USA; or by email at info@caru.bbb.org.

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

12. 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 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.

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Supplemental Kids' Privacy Notice

Last updated April 16, 2018

Effective May 25, 2018

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

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

  2. How do we use and share 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 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 share that information for the same purposes, as described in the general Privacy Notice.

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 share 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 share that information for the same purposes, as described in the general 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.

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.

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.

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 http://support.pokemon.com 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 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 http://support.pokemon.com 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 http://asrcreviews.org/asrc-contact-us/; by mail at CARU, Attn.: COPPA Safe Harbor Program, 112 Madison Avenue, New York, NY 10016 USA; or by email at info@caru.bbb.org

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

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