<p>Last updated November 12, 2020</p>
<p>Our Privacy Commitment</p>
<p>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.</p>
<p>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.</p>
<p>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.</p>
<p>
<em>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.”).</em>
</p>
<ol>
<li>
<p>What does this Privacy Notice cover?</p>
</li>
<li>
<p>What personal information is collected about you?</p>
</li>
<li>
<p>How is your personal information used?</p>
</li>
<li>
<p>How is your personal information shared?</p>
</li>
<li>
<p>How long do we keep your personal information?</p>
</li>
<li>
<p>What choices do you have about processing your personal information?</p>
</li>
<li>
<p>What steps do we take to safeguard your personal information?</p>
</li>
<li>
<p>Product-specific data processing details</p>
</li>
<li>
<p>Information for individuals</p>
</li>
<li>
<p>How to contact us about your personal information and this Privacy Notice</p>
</li>
<li>
<p>CARU's COPPA Safe Harbor Program</p>
</li>
<li>
<p>California Privacy Rights</p>
</li>
<li>
<p>How will you know if we amend this Privacy Notice?</p>
</li>
</ol>
<p>
<strong>1.
What does this Privacy Notice cover?</strong>
</p>
<p>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.</p>
<p>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.
Our
Services use YouTube API Services.
Please visit YouTube's
Terms of Service and Google's Privacy Policy
for more information.</p>
<p>
<strong>2.
What personal information is collected about you?</strong>
</p>
<p>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.</p>
<p>
<strong>
<em>Information you provide to us</em>
</strong>
</p>
<p>The types of personal information we collect directly from you include, for example: </p>
<ul>
<li>
<p>Contact information: such as your first and last name, email address, telephone number, postal address, and non-Pokémon account IDs.</p>
</li>
<li>
<p>Content and files: data and content you share or upload, such as photos (including any metadata included in your photos and content).</p>
</li>
<li>
<p>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.</p>
</li>
<li>
<p>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.</p>
</li>
</ul>
<p>
<strong>
<em>Information we collect automatically</em>
</strong>
</p>
<p>We automatically collect certain information when you use our Services.
For example:</p>
<ul>
<li>
<p>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.</p>
</li>
<li>
<p>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.</p>
</li>
<li>
<p>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.</p>
</li>
</ul>
<p>
<strong>
<em>Information we create or generate</em>
</strong>
</p>
<p>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.</p>
<p>
<strong>
<em>Information we obtain from third-party sources</em>
</strong>
</p>
<p>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:</p>
<ul>
<li>
<p>Non-Pokémon account operators: please see <strong>Play! Pokémon</strong> section below;</p>
</li>
<li>
<p>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 or screen name 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;</p>
</li>
<li>
<p>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</p>
</li>
<li>
<p>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 measuring public reaction to the Services and to Pokémon.</p>
</li>
</ul>
<p>
<strong>
<em>Cookies and Tracking</em>
</strong>
</p>
<p>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.</p>
<p>
<strong>3.
How is your personal information used?</strong>
</p>
<p>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:</p>
<ul>
<li>
<p>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.</p>
</li>
<li>
<p>Product and Service Delivery: to personalize content and experiences on our Services, including providing you recommendations based on your preferences;</p>
</li>
<li>
<p>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;</p>
</li>
<li>
<p>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;</p>
</li>
<li>
<p>Communications: to send and display administrative communications about Pokémon and our partners and our respective products and services;</p>
</li>
<li>
<p>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</p>
</li>
<li>
<p>Customer Support: to provide customer support and respond to your questions submitted to us.</p>
</li>
</ul>
<p>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.</p>
<p>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.</p>
<p>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.</p>
<p>
<strong>4.
How is your personal information shared?</strong>
</p>
<p>We do not share your personal information with third parties other than as follows:</p>
<ul>
<li>
<p>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</p>
</li>
<li>
<p>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 <em>all</em> of the categories of personal information described in Section 2.</p>
</li>
<li>
<p>If you've selected options available through our Services to publicly display your name and/or screen name and your other information</p>
</li>
<li>
<p>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</p>
</li>
<li>
<p>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</p>
</li>
</ul>
<p>
<strong>5.
How long do we keep your personal information?</strong>
</p>
<p>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.</p>
<p>
<strong>6.
What choices do you have about processing your personal information?</strong>
</p>
<p>We provide you with various controls over your personal information, for example:</p>
<ul>
<li>
<p>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.</p>
</li>
<li>
<p>You can contact us at privacyquestions@pokemon.com with requests to delete, access, and update your personal information.</p>
</li>
<li>
<p>You can opt out of our promotional emails by clicking “unsubscribe” in those emails.</p>
</li>
<li>
<p>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.</p>
</li>
<li>
<p>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/.</p>
</li>
<li>
<p>You can opt out of our advertising on mobile apps by using the advertising settings in your mobile device.</p>
</li>
<li>
<p>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.</p>
</li>
</ul>
<p>
<strong>7.
What steps do we take to safeguard your personal information?</strong>
</p>
<p>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.</p>
<p>
<strong>8.
Product-specific data processing details</strong>
</p>
<p>The following are product-specific details to supplement the information in this Privacy Notice.</p>
<p>
<strong>
<em>Play! Pokémon</em>
</strong>
</p>
<p>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 screen name, full
name, or first name and last initial in the player rankings.
If you choose not
to create a Pokémon Trainer Club 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.</p>
<p>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.</p>
<p>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.</p>
<p>
<strong>
<em>Pokémon Apps</em>
</strong>
</p>
<p>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.</p>
<p>
<strong>
<em>PokemonCenter.com</em>
</strong>
</p>
<p>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 and for fraud prevention.
Please review their respective privacy notices
to understand how they use your information.
PokemonCenter.com's services are
intended for customers in the United States and Canada.
For more information,
please refer to the PokemonCenter.com
Terms of Use.
</p>
<p>
<strong>9.
Information for individuals</strong>
</p>
<p>You have the following rights:</p>
<ul>
<li>
<p>A right to be informed of the ways in which we use your information.</p>
</li>
<li>
<p>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.</p>
</li>
<li>
<p>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.</p>
</li>
<li>
<p>A right to object to the processing of your personal data or obtain a restriction of such processing under certain circumstances.</p>
</li>
<li>
<p>A right to have your personal data transferred to another organization should it be technically feasible for Pokémon to do so.</p>
</li>
<li>
<p>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)</p>
</li>
<li>
<p>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.</p>
</li>
</ul>
<p>To make such requests, contact us at privacyquestions@pokemon.com or https://support.pokemon.com/hc/requests/new?ticket_form_id=360000012406.</p>
<p>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.</p>
<p>We transfer personal data from the EEA, the United Kingdom
(UK), 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.
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 data
to comply with a legal obligation or legal process, we will take reasonable steps
to ensure that we disclose only the minimum personal data 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 data 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.
</p>
<p>We also participate in the EU-U.S.
Privacy Shield Framework
and Swiss-U.S.
Privacy Shield Framework.
Although the EU-U.S.
Privacy Shield
has been ruled invalid as a legal basis for data transfers to the U.S., we
continue to comply with the Privacy Shield Principles with respect to all
personal information transferred from the European Union, the United Kingdom,
and/or Switzerland to the United States in reliance on the Privacy Shield.
If
there is any conflict between the terms in this Privacy Notice and the Privacy
Shield Principles, the Privacy Shield Principles shall govern.
</p>
<p>We are subject to the investigatory and enforcement powers
of the U.S.
Federal Trade Commission.
If third-party agents process personal
data on our behalf in a manner inconsistent with the Privacy Shield Principles,
we remain liable unless we prove we are not responsible for the event giving
rise to any damages.
European Union,
United Kingdom, or Swiss individuals with inquiries or complaints regarding our
adherence to Privacy Shield Principles 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.
Pursuant with the Privacy Shield
Principles, EU, UK and Swiss individuals have the right to access their
personal data that is transferred into the United States.
Individuals can update or correct inaccurate
information or request erasure of data that has been processed in violation of
the Frameworks.
Individuals wishing to exercise this right may do so by
contacting Pokémon using the details in this section.
</p>
<p>For any complaints that cannot be resolved with us directly,
you may refer the matter to the BBB EU PRIVACY SHIELD, operated by BBB National
Programs, Inc.
If you have contacted Pokémon and 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 EU Privacy Shield.
This
service is provided free of charge to you.
If your complaint remains unresolved
after contacting Pokémon, and the BBB EU Privacy Shield, you also have a right
to lodge a complaint with a supervisory authority.
</p>
<p>If your Privacy Shield complaint cannot be resolved through
the above channels, under certain conditions, a binding arbitration option may
be available to you.</p>
<p>If you are an employee of Pokémon and your personal human
resource related data is transferred from the EEA, United Kingdom and/or
Switzerland to the United States, and you have a complaint regarding the transfer of your personal
human resource data that is within the context of your employment relationship to
other countries or regions, some of which have not been determined by the
European Commission to have an adequate level of data protection, please refer
to your Employee Privacy Notice for further instructions on filing a complaint.</p>
<p>
<strong>10.
How to contact us about your personal information and this Privacy Notice</strong>
</p>
<p>If you have questions or comments about our data practices or this Privacy Notice, you can contact us or our data protection officer at:</p>
<p>The Pokémon Company International, Inc.<br>
Attn.: Data Protection Officer</p>
<p>10400 NE 4th Street<br>
Suite 2800 <br>
Bellevue, WA 98004<br>
USA</p>
<p>3<sup>rd</sup> Fl Bldg 10, Chiswick Park<br>
566 Chiswick High Road<br>
London, W4 5XS<br>
United Kingdom</p>
<p>privacyquestions@pokemon.com</p>
<p>
<strong>11.
CARU's COPPA Safe Harbor Program</strong>
</p>
<p>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.</p>
<p>Please note that CARU is not affiliated with Pokémon and
cannot help you with non-privacy-related issues.</p>
<p>
<strong>12.
California Privacy Rights</strong>
</p>
<p>This section provides you with additional disclosures
required under California law.</p>
<p>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.</p>
<p>Pokémon does not sell your personal information as defined
by the CCPA and has not done so in the past 12 months.</p>
<p>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.</p>
<p>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.</p>
<p>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.</p>
<p>
<strong>13.
How will you know if we amend this Privacy Notice?</strong>
</p>
<p>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.</p>
<p>back to top</p>
<p>
<strong>Supplemental Kids' Privacy Notice</strong>
</p>
<p>Last updated May 25, 2018</p>
<p>Effective May 1, 2019</p>
<p>
<strong>OUR ADDITIONAL PRIVACY COMMITMENT TO KIDS AND THEIR PARENTS</strong>
</p>
<p>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.</p>
<p>TABLE OF CONTENTS</p>
<ol>
<li>
<p>What types of information do we collect about kids?</p>
</li>
<li>
<p>How do we use and share the personal information that we collect from kids?</p>
</li>
<li>
<p>How do we notify and obtain consent from parents for the collection of personal information from their kids?</p>
</li>
<li>
<p>How can parents access, change, or delete personal information about their kids?</p>
</li>
<li>
<p>How will we notify parents if our Kids' Privacy Notice changes?</p>
</li>
<li>
<p>CARU's COPPA Safe Harbor Program</p>
</li>
</ol>
<p>
<strong>1.
What types of information do we collect about kids?</strong>
</p>
<p>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.</p>
<p>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.</p>
<p>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.</p>
<p>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.</p>
<p>Pokémon does not condition participation in any of its
Services for kids on the collection of more personal information than is
reasonably necessary.</p>
<p>
<strong>2.
How do we use and share the personal information that we collect from kids?</strong>
</p>
<p>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:</p>
<ul>
<li>
<p>Link an account from one of Pokémon's Services with an account from another Service operated by Pokémon or an affiliate of Pokémon</p>
</li>
<li>
<p>Participate in games, reward programs, contests, sweepstakes, events, or promotions</p>
</li>
<li>
<p>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</p>
</li>
<li>
<p>Participate in polls, surveys, or questionnaires</p>
</li>
<li>
<p>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</p>
</li>
<li>
<p>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)</p>
</li>
</ul>
<p>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.</p>
<p>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.</p>
<p>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.</p>
<p>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.</p>
<p>Pokémon shares kids' personal information with the same
entities and for the same purposes described in the general Privacy Notice.</p>
<p>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 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.</p>
<p>
<strong>3.
How do we notify and obtain consent from parents for the collection of personal information from their kids?</strong>
</p>
<p>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.</p>
<p>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.</p>
<p>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.</p>
<p>
<strong>4.
How can parents access, change, or delete personal information about their kids?</strong>
</p>
<p>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.</p>
<p>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.
</p>
<p>
<strong>5.
How will we notify parents if our Kids' Privacy Notice changes?</strong>
</p>
<p>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.</p>
<p>
<strong>6.
CARU's COPPA Safe Harbor Program</strong>
</p>
<p>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.</p>
<p>Please note that CARU is not affiliated with Pokémon and cannot help you with non-privacy-related issues.</p>
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