This Privacy Notice applies to personal information processed by us, including on our websites, mobile applications, blog and other online or offline offerings. To make this Privacy Notice easier to read, our websites, mobile applications, blog and other offerings are collectively called “Services.”

We may revise this Privacy Notice from time to time in our sole discretion. Any changes will become effective when we post the revised Privacy Notice on the Services. You understand and agree that you will be deemed to have accepted the updated Privacy Notice if you continue to use our Services after the new Privacy Notice takes effect.

The categories of personal information we collect depend on how you interact with us, our Services and the requirements of applicable law. We collect information that you provide to us, information we obtain automatically when you use our Services, and information from other sources such as third-party services and organizations, as described below. Additionally, we do not collect, use, disclose, sell, or share any of your sensitive personal information.

A. Information You Provide to Us Directly

To offer our users certain features of our Services, and to create certain user accounts (e.g., to create a game account), we collect several types of personal information from you directly. Typically, this information includes:

• ・Username (User ID): The name and identifier you choose for your account
• ・Email address: Used for account communication and, where applicable, transactional notices
• ・Date of birth or age range: Used for age verification and to apply age-appropriate features or restrictions
• ・User-generated content and communications: Content you submit via messaging, chat (including in-game guild or open chat), forums, or our social media pages (see Section 5 for visibility)
• ・Payment-Related Information(user-submitted): When you make a purchase, you provide information related to your chosen payment method and contact details for transactional notices (e.g., email for receipts). Payment card numbers and security codes are entered into and processed by our payment processor; we do not receive or store your full PAN or CVV.
• ・Other information you submit to help us deliver and support your experience: For example, support inquiries or survey responses

B. Information Collected Automatically

We collect your personal information automatically when you use our Services, including sometimes through cookies and other Web-Based Technologies. Typically, this information includes:

• ・Device and Network Identifiers: e.g., IP address, device ID, Advertising ID, etc.
• ・Service Usage Details: information about how you interact with the game. This includes Gameplay Data – for example, your player progress, achievements, in-game items or rewards you obtain (including items granted via a purchased Pass), and quests or events you participate in – as well as Log Data (technical logs, error reports) and Usage Statistics. We may also collect limited communications metadata (e.g., time sent, participant identifiers, delivery status) to operate, secure, and moderate chat and social features.
• ・Location Information. We may collect precise location information, such as location information from your mobile device or otherwise use our Services if you opt in to permit us to do so.
• ・Cookies and Similar Technologies. We, as well as third parties that provide content, advertising, or other functionality on our Services, may use cookies, pixel tags, local storage, and other technologies (“Technologies”) to automatically collect information through your use of our Services.
• ・Types. Cookies (small text files stored in your browser), local storage and SDKs (on-device components enabling features and measurement), and pixel tags/web beacons (code on pages or emails that records engagement, such as page visits or email opens)
• ・Purposes.
• ・Operationally Necessary. This includes Technologies that allow you access to our Services, applications, and tools that are required to identify irregular website behavior, prevent fraudulent activity and improve security or that allow you to make use of our functionality;
• ・Performance-Related. We may use Technologies to assess the performance of our Services, including as part of our analytic practices to help us understand how individuals use our Services (see Analytics below);
• ・Functionality-Related. We may use Technologies that allow us to offer you enhanced functionality when accessing or using our Services. This may include identifying you when you sign into our Services or keeping track of your specified preferences, interests, or past items viewed;
• ・Advertising- or Targeting-Related. We may use first-party or third-party Technologies to deliver content, including ads relevant to your interests, on our Services or on third-party websites.

See Section 6 below to understand your choices regarding these Technologies.

• ・Analytics. We use cookies, SDKs, logs, and other third-party tools to measure and improve our Services (e.g., usage metrics, performance diagnostics). You can manage your choices in the Cookies and Analytics portions of Section 6. If we use Google Analytics, please see Google’s Privacy Policy and its opt-out resources.
• ・Moderation and Safety Tools. To help maintain a safe environment, we may use automated tools and/or service-provider SDKs to detect, filter, and flag content that may violate our policies (e.g., profanity filtering, anti-spam, safety heuristics), as further described in Section 4. Where necessary, these tools may apply temporary, precautionary restrictions on content or accounts and generate limited safety signals (e.g., rule-match indicators or risk scores) that we retain for a short period to operate and improve these features. Any final account suspension or termination requires meaningful human review (see Section 4 and Profiling).
• ・Social Media Platforms. Our Services may contain social media buttons such as Facebook (that might include widgets such as the “share this” button or other interactive mini programs). These features may collect your IP address, which page you are visiting on our Services, and may set a cookie to enable the feature to function properly. Your interactions with these platforms are governed by the privacy policy of the company providing it.

C. Information Collected from Other Sources

We may obtain information about you from other sources, including third-party service providers. For example:

• ・Payment Processors. We may receive transaction results, limited card metadata, fraud-prevention signals, and other information necessary to complete payments, issue refunds, and prevent abuse. We do not receive or store your full payment card number or security code. When you complete a purchase, we may receive information from payment processors to facilitate the transaction.
• ・In-App Purchases (via platform providers). For in-app purchases, we receive platform-issued receipts, purchase tokens, and other transaction identifiers to verify purchases, process refunds, and detect fraud. Platform providers may not supply contact information (e.g., purchaser email) to us; the exact information we receive depends on each platform’s policies and technical specifications.
• ・Analytics Providers. We receive data from third-party analytics providers regarding your usage of our Services.
• ・Age Verification Providers. For age verification, we may receive an age-affirmation (e.g., a token or age range) from a verification provider; we do not receive or retain underlying verification documents provided to such provider.

A. Disclosures to Provide our Services

The categories of third parties with whom we may share your information are described below.

• ・Service Providers. We may share your personal information with our third-party service providers who use that information to help us provide our Services. This includes service providers that provide us with IT support, hosting, payment processing, customer service, and related services (including age‑verification providers and content moderation/safety service providers).
• ・Payment Processors and Platforms. We disclose payment-related information to payment agents and platform providers (including app store operators) to the extent necessary for processing transactions, handling refunds, and preventing fraud.
• ・Group Companies/Affiliates. We may share your personal information with our company affiliates.
• ・Advertising Partners. We may share your personal information with third-party advertising partners. These third-party advertising partners may set Technologies and other tracking tools on our Services to collect information regarding your activities and your device (e.g., your IP address, cookie identifiers, page(s) visited, time of day). These advertising partners may use this information (and similar information collected from other services) for purposes of delivering personalized advertisements to you when you visit digital properties within their networks. This practice is commonly referred to as “interest-based advertising” or “personalized advertising.”
• ・Other Users / Public Areas. Content you post or send in open or guild chats, forums, or other public or semi‑public areas of the Services will be visible to other users. Do not share personal information (e.g., real name, address, phone number, payment details) in these areas. We cannot control how other users may use content you choose to make public.
• ・APIs/SDKs. We may use third-party Application Program Interfaces ("APIs") and software development kits ("SDKs") as part of the functionality of our Services(including for analytics, advertising, age verification, and safety/moderation features). For more information about our use of APIs and SDKs, please contact us as set forth in Section 14 below.

B. Disclosures to Protect Us or Others

We may access, preserve, and disclose any information we store associated with you to external parties if we, in good faith, believe doing so is required or appropriate to: comply with law enforcement or national security requests and legal process, such as a court order or subpoena; protect your, our, or others’ rights, property, or safety; enforce our policies or contracts; collect amounts owed to us; or assist with an investigation or prosecution of suspected or actual illegal activity (including reviewing relevant communications or logs where necessary and proportionate).

C. Disclosure in the Event of Merger, Sale, or Other Asset Transfers

If we are involved in a merger, acquisition, financing due diligence, reorganization, bankruptcy, receivership, purchase or sale of assets, or transition of service to another provider, your information may be sold or transferred as part of such a transaction, as permitted by law and/or contract.

• ・Mobile Devices. We may send you push notifications through our mobile application. You may opt out of receiving these push notifications by changing the settings on your mobile device.
• ・Cookies and Interest-Based Advertising. You may stop or restrict the placement of Technologies on your device or remove them by adjusting your preferences as your browser or device permits. However, if you adjust your preferences, our Services may not work properly. Please note that cookie-based opt-outs are not effective on mobile applications. However, you may opt-out of personalized advertisements on some mobile applications by following the instructions for Android, iOS and others.
  For more information about setting cookies, visit here.
  Please note you must separately opt out in each browser and on each device.
• ・“Do Not Track.” At this time, our websites do not recognize browser-based “Do Not Track” instructions. You can, however, change your privacy preferences regarding the use of cookies and similar technologies through your browser, as mentioned above.

• ・Access Personal Information about you, including: (i) confirming whether we are processing your personal information; (ii) obtaining access to or a copy of your personal information; and (iii) receiving an electronic copy of personal information that you have provided to us, or asking us to send that information to another company (the “right of data portability”);
• ・Request Correction of your personal information where it is inaccurate or incomplete. In some cases, we may provide self-service tools that enable you to update your personal information;
• ・Request Deletion of your personal information;

Categories of personal information we collect
U.S. residents have the right to know what categories of personal information we collected about them and whether we disclosed that personal information for a business purpose (e.g., to a service provider) in the preceding 12 months. U.S. residents can find this information below:

Category of Personal Information Collected by Us	Category of Third Parties Information is Disclosed to for a Business Purpose
Identifiers. Examples: User ID, Player name, Email address, IP address, Device identification number, Date of birth or age range (for age verification and age‑appropriate features), Purchase token, Receipt/Transaction ID	・Group Companies ・Advertising networks ・Data analytics providers ・Service Providers ・Payment processors; Platform providers (including app store operators)
Protected classification characteristics under California or federal law Examples: Age (40 years or older), Sex (including gender, gender identity)	・Group Companies ・Service Providers
Commercial information Examples: Products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies, Product ID, Purchase date, Transaction ID, Subscription status	・Group Companies ・Advertising networks ・Data analytics providers ・Service Providers ・Payment processors; Platform providers (including app store operators)
Geolocation data Example:Physical location or movements.	・Group Companies ・Advertising networks ・Data analytics providers ・Service providers
Internet or other similar network activity Examples: Browsing history, Search history, Information on a consumer's interaction with an internet website, application, or advertisement	・Group Companies ・Advertising networks ・Data analytics providers ・Service Providers
Professional or employment-related information Example: Occupation	・Group Companies ・Service Providers

The categories of sources from which we collect personal information and our business and commercial purposes for using personal information are set forth above.

“Sales” or “Share” of Personal Information under the State Privacy Law

We do not “sell” personal information. With respect to “sharing” personal information for cross‑context behavioral advertising, to the extent our activities fall within the definition of “share,” we provide a right to opt‑out and will honor your opt‑out choices (see Sections 6 and 14). We also do not knowingly “share” personal information of consumers under 16 without affirmative authorization (opt‑in).

Additional Privacy Rights for U.S. Residents

You may exercise the following rights by contacting us or a representative or data protection officer. If you request to exercise the following rights, please contact us as set forth in section 14 below.

• ・Non-Discrimination. U.S. residents have the right not to receive discriminatory treatment by us for the exercise of their rights conferred by respective State Privacy Laws.
• ・Authorized Agent. Only you, or someone legally authorized to act on your behalf, may make a verifiable consumer request related to your personal information. You may also make a verifiable consumer request on behalf of your minor child. To designate an authorized agent, please contact us as set forth in section 14 below.
• ・Verification. To protect your privacy, we will take steps the following steps to verify your identity before fulfilling your request. When you make a request, we will ask you to provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative.
• ・Appeal. If we decline to take action on a privacy request, you may have the right to appeal. Instructions for submitting an appeal will be provided in our response.

If you are a U.S. resident and would like to exercise any of your rights under respective State Privacy Laws, please contact us as set forth in Section 14 below. We will process such requests in accordance with applicable laws.

• ・California Shine the Light. We are exempted from the requirement to grant such a request because we do not disclose personal information of customers to third parties’ direct marketing purposes unless a customer directs to us.
• ・Privacy Rights for California Minors in the Digital World. If you are under the age of 18, you have the right to request permanent deletion of the reviews of products you posted on our service. Please note that when you post the reviews they can be collected, stored, or shared by others, and we cannot delete such information held by others. If you request to exercise the above rights, please contact us as set forth in section 14 below.

No obligation to provide your personal data

You have no obligation to provide your personal data to us either under applicable law or a contract. Once you make an order for our services, we may require your personal data based on the contract with you, in which case your failure to provide the personal data we require may prevent us from providing you with the services.

Profiling

We do not make decisions based solely on automated processing (including profiling) that produce legal effects or similarly significantly affect you. Our automated safety systems may algorithmically detect patterns and, where necessary, apply temporary, precautionary restrictions (e.g., content visibility limits or temporary account holds) to protect users and the Service.

Any final decision to suspend or terminate an account requires meaningful human review. You may request human intervention, express your point of view, obtain an explanation of the decision, and contest any restriction or enforcement action, as permitted by applicable law. Please use the contact channels in Section 14 (Contact Us); we will review and respond within a reasonable time.

We process limited signals for these safety purposes under our legitimate interests (e.g., maintaining a safe and secure community, preventing fraud/abuse, and enforcing our Terms) and apply appropriate safeguards, including proportionality, data minimisation, and retention limits for related logs.

Additional Privacy Rights for EU/UK Residents

You may exercise the following rights by contacting us or a representative or data protection officer. If you request to exercise the following rights, please contact us as set forth in section 14 below.

• ・Right to erasure. You may obtain the erasure of your personal data, subject to certain exceptions under the GDPR, where: (i) such personal data is no longer necessary in relation to the purposes for which we collected and processed it; (ii) you withdraw your consent to our processing solely based upon your consent; (iii) you object to our processing and there are no overriding legitimate grounds for such processing; (iv) our processing is unlawful; (v) your personal data has to be erased in compliance with a legal obligation.
• ・Right to restriction of processing. You may obtain restriction of processing of your personal data, subject to certain exceptions under the GDPR, where: (i) you contest the accuracy of your personal data: (ii) our processing is unlawful and you select to restrict our processing instead of requesting erasure of your personal data: (iii) you request us to establish, exercise or defense legal claims that need your personal data no longer necessary for the purposes of our processing; or (iv) you exercise the right to object to our processing and wait for verification on where we have overriding legitimate grounds.
• ・Right to data portability. You may receive your personal data or direct us to transmit your personal data to a third party you designate, provided that we process such personal data based upon your consent or as the performance of a contract with you.
• ・Right to object. You may object to the processing of your personal data where our processing is based upon the exercise of our official authority or our legitimate interests, including “profiling” or for direct marketing purposes.
• ・Right to the withdrawal of your consent. You may withdraw your consent at any time to the processing of your personal data that we have collected about you. The legality of processing based on consent prior to withdrawal will not be affected by the withdrawal of consent.
• ・Right to complain. You may lodge a complaint with the supervisory authority, in particular, in the member state of the EU or the UK where you have a habitual residence or place or work or where the alleged infringement of GDPR took place.

• ・Representative
  Our representative in the EU/UK is Classmethod (Europe) GmbH. You can contact our representative at;
  
  Mail: Krausenstr.9 -10, 10117 Berlin, Germany
  Email: rh@gdpr-contact.email


• ・Data Protection Officer
  You can contact our Data Protection Officer at;
  
  Mail: 1-6-1 Yotsuya, Shinjuku-ku, Tokyo 160-0004
  Email: dpo@reazon.jp