Effective Date: September 18, 2019

In this Privacy Policy, "DeNA", "we", "us", or "our" means DeNA Co., Ltd. and its subsidiaries.

Your privacy is important to DeNA. We designed our Privacy Policy to cover how we collect and use your information in connection with use of our mobile game software and media dedicated to that software ("Services"). By using our Services, you agree to our collection and use of your information, including your personal information, as described in this Privacy Policy. This Privacy Policy should be read together with our End-User License Agreement (“EULA”).

So please take a moment to learn the five W's, the How, and other important matters about the information we collect and how we use it. If you have any questions, please contact us.

Contents

• The What

  Both non-personal information and personal information may be collected and used by us.

• The Why

  The primary objective for our collection and use is to deliver and improve our Services.

• The When

  When you provide information to us, use the Services, or register or connect with a social gaming network or other social network service ("SNS") in connection with use of our Services.

• The How

  By providing information to us directly, using the Services, or registering or connecting with an SNS in connection with use of our Services.

  We may also use cookies and other electronic means to collect your personal information, but options are available to remove/disable certain cookies by the settings on your browser.

  Services-related promotions (including SMS) may also be used by us; if you opt in, or as permitted by law, these services may include the sending of commercial electronic messages.

• The Who

  We may share your information with persons who help us provide the Services, but only as necessary, and only to persons who are bound contractually to keep the information confidential, use it only to assist us in providing the Services, and protect using appropriate security safeguards.

  Except only in special circumstances, we never transfer your personal information to advertisers or marketers for their own use without your separate consent.

  We do not knowingly collect personal information from children under 13.

• The Where

  In line with this Privacy Policy, your information may be processed in Japan, the United States and other countries, as necessary, where it may be subject to laws different than your home country.

• Changes to Privacy Policy

  We may change this Privacy Policy in accordance with the procedures set out below, so please check for any updates.

• Your Choices

  You have certain options with respect to how your personal information may be used or disclosed.

• Other Important Matters

  Measures are taken to safeguard information received from you, and we keep your personal information only as long as necessary.

The What

In the course of using our Services, you may provide us, directly and indirectly, with both personal and non-personal information. Personal information includes any factual or subjective information that can be used, on its own or in combination with other information, to identify you as an individual, and might include your name, phone number, pictorial representation, email address, postal address, opinions, comments, age, etc. Non-personal information is information that does not permit direct association with you, including personal information which has been aggregated with other users’ information such that it can no longer be attributed to any individual. Certain non-personal information would be considered a part of your personal information if it were combined with other identifiers (e.g., combining your zip or postal code with your street address) in a way that enables you to be identified. But the same pieces of information are considered non-personal information if they are taken alone or combined only with other non-personal information (e.g., your viewing preferences), provided the information cannot otherwise be linked or attributed back to you as an identifiable individual.

The Why

Our primary objective in collecting your information is to provide you with a superior and personally relevant user experience. To achieve this, your information may be used as follows or by requesting explicit consent where required by law:

- To help us develop, deliver (in accordance with the EULA), and improve our Services, including the following aspects of our Services:

• messaging and other communication to and with users
• the creation, updating, accessing, and maintaining of lists of friends or contacts
• transactions for and use of virtual currency and virtual items
• communication and user-interactive features
• for purposes of tracking achievements on game platforms
• where consent is necessary, the delivery and targeting of advertising in the Services
• tracking of advertisement fulfillment metrics in the Services
• authentication purposes
• recommending Services-related products or services of interest directly to you

- For market research purposes that support our efforts to deliver a more valuable service to our community of users, and to contact you with announcements, newsletters, and promotional materials related to our Services or to offer you opportunities to participate in surveys, contests, or sweepstakes (any of these a "Promotion") via our Services.

- To provide end-user support.

- To prevent and take measures against fraud, illegal activities, infringement of our rights or interests, or breaches of our EULA and this Privacy Policy.

- To send important notices, such as changes to our EULA, this Privacy Policy, or other Services-specific policies. Because this information is important to your interactions with us, you may not opt out of receiving these communications.

- To audit and analyze data for technical administration, to improve our Services, and for end-user communications.

The When

Your information is collected by us when you directly interact with our Services, including by filling out your user profile in our application, and otherwise through use of our Services via the device you use to access or use our Services ("Device").

Your information may also be made available to us when you register with any Account System for use of our Services and/or permit any Account System to share any of your information with us in connection with your use of our Services, including account ID, country, region, language and username, and when any changes are made to that information. By accepting an Account System's applicable terms, you agree for the Account System to make such information available to us on those terms.

When you use our Services, we collect information related to your Device as described in "The How" section below.

If you choose to participate in a Promotion, we may request that you provide us with personal information such as your email address or postal address in order to administer your participation in the Promotion.

The How

As already mentioned, we may collect information from you when you directly interact with our Services and otherwise indirectly through your access to or use of our Services. You may have certain options to control the use of these technologies – see Your Choices.

Direct interaction may include such actions as creating a username, or creating a friends' list. It may also include the sending of invites to become “friends” for the purpose of entering a battle together. We may but are not required, to collect and store the information referred to in this paragraph.

We may also collect your information from SNS’s or other third parties who provide it to us, including other users of our Services and, as noted above, any Account System you engage with related to our Services.

As is standard practice, we do use "cookies" in connection with the Services. A cookie is a small string of text placed on your Device. In addition to strictly necessary cookies that enable us to provide our Services (such as those that provide your Account System log-in status when that account ID is linked to functionality on the Services), we may use both performance-gauging and functionality-gauging cookies. Performance-gauging cookies reveal how you use the Services, for instance, which content is the most popular, how much time users are spending there, and what advertising is relevant to you, which helps us provide an optimized experience (we may engage third parties to carry out this analysis, and they may set their own "third party" cookies--see "The Who" for more). Functionality-gauging cookies enables us to remember certain choices you make in interacting with the Services, for instance, any geographic location, language, or fonts you choose, which helps us tailor the Services to your preferences. Neither performance-gauging cookies nor functionality-gauging cookies collect information in any way that personally identifies you.

Except for cookies strictly necessary to enable us to provide our Services, you have the option to disable cookies stored on your browser by changing the options in your browser to stop accepting cookies or to prompt you before accepting a cookie from the content you visit. If you do not accept cookies, you may not be able to view or use parts of our Services due to limited functionality. Some cookies we use may be stored using a web-browsing component other than a browser application--these cannot be disabled on your Device, but the information collected does not personally identify you, and does not permit tracking between Services.

Some of our Services, including messaging, may use "click-through URLs" linked to other content on our Services. We track this click-through data in aggregate to help us determine interest in topics, Services usability, and other measures of user engagement.

In using our Services, our servers record information sent from your Device such as device name, mobile carrier, operating system, application version, personal settings (such as language and advertising tracking settings), Internet Protocol ("IP") address, device and advertiser identifiers (such as IDFA, AAID), cookies identifier, network type, time zone, log information (such as site access history and information about how you interact with game) and usage information (such as game user ID, game data, game play related information (including payment amount), and crash log data).

BY ACCESSING OUR SERVICES, YOU ARE CONSENTING TO THE USE OF COOKIES AND THE OTHER ABOVE TECHNOLOGIES UNDER THE TERMS OF THIS PRIVACY POLICY.

The Who

Our Responsibility for Our Collections

We will collect and use your information as explained in this Privacy Policy. As a user of our Services you may be permitted to use and create your own profile, invite other users into a multi-user battle rooms, and send stamps/stickers to other users during battles.

Interaction with Other Users via Social Features

As mentioned in "The Why", social interaction may be a function that is offered as a part of our Services. You understand and agree that your profile may be viewable in the Services by other users if they enter your designated ID, used to become “friends” for purposes of entering a battle together in the Services. Such invitations are sent through the Services by entering the invitee's designated ID, which can only be communicated to other users outside of the Services. Other users of the Services will be able to see your profile information, which may includes your username, user level, avatar, favorite in-game assets, and last login time (users may choose to block others from seeing last login time). We are not responsible for the activities of other users or other third parties with whom you choose to provide your information or otherwise interact.

Persons with Whom We May Share Your Information

You agree that we may share your information as follows:

• With Third Parties for Industry Analysis and Advertising

You agree that we may share technical information related to your Device (such as IP address), aggregated non-personal information, and anonymous information with advertisers, ad networks, and analytics analysis entities ("Ad Entities") with whom we have strategic relationships, and Ad Entities may also be permitted to collect such information via cookies and other tracking technologies. This information may be used to undertake user trend analyses, demographic profiling, and analytics, and to provide to you tailored and personalized ads and advertising (behavioural advertising). Please note, though, that some Ad Entities also act as Service Providers (defined below) for us, and in those cases we may share your information as explained below.

• With our Service Providers

Sharing of your information may also occur where we engage or employ service providers, vendors, or other third parties to help us provide our Services (each a "Service Provider") (e.g., improvement of our Services' features, promotion and marketing, administration, analytics, customer service, cloud storage, hosting, and other related services), to provide the Services on our behalf, or to assist us in analyzing how our Services are being used. Our Service Providers may have access to your personal information only to perform these tasks on our behalf, and they are obligated not to disclose or use your personal information for any other purpose, and to protect your information to a level reasonably comparable with the safeguards we use.

• With Certain Third Parties in Special Circumstances

In some instances, we may disclose information about you where legally permitted, including to law enforcement officials or private parties if we believe it is necessary or appropriate to respond to claims and legal process (including subpoenas), to protect the property and rights of DeNA or a third party, to protect the safety of the public or any person, or to prevent or stop activity we may consider to be, or to pose a risk of being, illegal, unethical, or legally actionable activity.

In other cases, for example, in connection with a merger, acquisition, reorganization, or sale of assets, or in the event of bankruptcy, we may sell or transfer some or all of our assets. In connection with such a transaction, we may transfer all of the information about you in our records, including personal information, to any successor entity.

Policy Not to Collect Personal Information from Children

We do not knowingly collect personal information from, or store personal information of, children under the age of 13. We will upon notice or discovery take all reasonable efforts to erase or destroy any such personal information that may have been collected or stored by us without our knowledge or consent.

The Where

You understand and agree that we may transfer your information to and process it in Japan, the United States and other countries outside of your country of residence. Such transfer could subject the user’s personal information to foreign laws, which may provide different levels of protection than those in your home country.

Changes to Privacy Policy

We reserve the right to change, amend or modify this Privacy Policy at any time. If we change this Privacy Policy in a material way, we will give notice of that in the Services, on our website (https://dena.com/legal/), and/or by email to any email address we may have for you at that time. Your use of our Services after we have changed the Privacy Policy will indicate your consent to the updated Privacy Policy.

Other Important Matters

Push and Local Notifications

Unless you indicated otherwise at installation or chose not to receive push notifications, we may send push and local notifications to your Device concerning updates, events, and special offers for our mobile games and other mobile applications of the Services installed on your Device. Please note that you have the option of deactivating push or local notifications by changing the settings of the game/application or of your Device.

Protecting Your Information

We take your privacy very seriously and employ reasonable administrative, physical, and electronic measures designed to safeguard information received from you and held by us against identity theft and unauthorized access or alteration. In addition, we will take reasonable steps to assure that third parties to whom we transfer any data will provide comparable protection of your personal information. We do not and will not, at any time, request your credit card information, login password, or any national identification numbers in a non-secure or unsolicited communication (e.g., via e-mail, telephone, or mobile device). We will not keep your personal information any longer than needed for the purpose it was collected or than is necessary for legal or legitimate business purposes.

We will make any legally required disclosures of any breach of the security, confidentiality, or integrity of your unencrypted electronically stored "personal data" or "personal information" (as defined in applicable statutes on security breach notification) to you via email or conspicuous posting on our website in the most expedient time possible and without unreasonable delay, consistent with (i) the legitimate needs of law enforcement; or (ii) any measures necessary to determine the scope of the breach and restore the reasonable integrity of the data system.

Corrections, Deletions and Requests for Information

If you have any concerns with the way we collect and handle your personal information, or would like to correct or request that we delete such personal information held by us, please contact us. We will use commercially reasonable efforts to honor your request; please note, though, that at a minimum we may retain an archived copy of your records as required or permitted by law or to send necessary communications to you under this Privacy Policy. You understand that deletion of your personal information may result in you not being able to view or use portions of our Services which depend on such information.

You are entitled, with certain legal restrictions, to access any personal information we hold about you. If you want to review, verify or correct your personal information, please contact us in writing using the contact information provided in the “Contacting Us” section below. We will respond within a reasonable timeframe or as required by law to all requests for access and review and either provide access to your personal information in our records, or, if permissible, explain why access is denied.

Your Choices

For a Promotion you have opted into, you have the option to opt out at any time from participation in such Promotion and the receipt of any related communications by following unsubscribe instructions provided in the relevant communications, or by selecting not to receive communications from us where the relevant media service offers that option.

For more information, including possible options you may have, on the use of behavioural advertising by Ad Entities generally, see, e.g., the Digital Advertising Alliance, the Network Advertising Initiative.

Other Websites and Services

Our Services may contain links to other websites and online services or offers from third parties. For example, our Services may include offers from third party advertisers or the ability to engage in transactions with such entities. If you choose to participate in offer-linked information requests or "click on" an advertisement or another third-party link, you may be directed to that third party's website or service and/or be prompted to provide personal information in connection with such activity.

The fact that we allow linking to a third-party website or service (including Account System, and optional mobile game recovery services) is not an endorsement or representation of our affiliation with that third party, nor is it an endorsement of such third party's privacy or information security policies or practices or their compliance with any laws. We do not exercise control over third party websites or services, and this Privacy Policy does not apply to information you provide or collected by them, including Ad Entities. These other websites or services may place their own cookies or other tracking devices on your computer or mobile device, or collect data or solicit personal information from you. Other websites and services follow different rules regarding the use or disclosure of the personal information you submit to them. We encourage you to read the privacy policies or statements of the other websites and services you use and the terms of the offers in which you participate. You agree that we are not responsible for, nor will we be liable to you or any third party for, your interaction with such third parties or the information requests initiated by such third parties or the subsequent use, treatment, or dissemination of the information you provide to them.

To the extent that any of our mobile applications of the Services collects personally identifiable information, that is done only as strictly necessary to enable us to provide those Services (see The How, above), and this cannot be disabled by "do not track" or other mechanisms available via your mobile Device's browser.

Contacting Us

If you have any questions, inquires, requests, or complaints concerning this Privacy Policy or our information collection practices, please contact us at [email protected] addressed to “App Specialist” or by post:

Attn: App Specialist, DeNA Customer Support Center,
Shibuya Scramble Square, 2-24-12 Shibuya, Shibuya-ku, Tokyo 150-6140, Japan

Effective Date: September 18, 2019

In this Privacy Policy, "DeNA", "we", "us", or "our" means DeNA Co., Ltd. and its subsidiaries.

Your privacy is important to DeNA. We designed our Privacy Policy to cover how we collect and use your information in connection with use of our multi-region entertainment software, and media dedicated to that software ("Services"). By using our Services you agree to our collection and use of your information, including your personal information, as described in this Privacy Policy. This Privacy Policy should be read together with our End-User License Agreement (“EULA”).

So please take a moment to learn the five W's, the How, and other important matters about the information we collect and how we use it. If you have any questions, please contact us.

Contents

• The What

  Both non-personal information and personal information may be collected and used by us

• The Why

  The primary objective for collection and use is to deliver and improve our Services

• The When

  When you provide information to us, use the Services, or register or connect with a social gaming network or other social network service ("SNS") in connection with use of our Services

• The How

  By providing information to us directly, using the Services, or registering or connecting with an SNS in connection with use of our Services

  Cookies may be used, but options are available to remove/disable certain cookies by the settings on your browser

  Services-related promotions (including SMS) may also be used by us, but you will have the option to opt-out of these

  Geo location information may be collected from the Device, but unless you opted in, this will not be collected or used in a way that identifies you

• The Who

  We may share your information with persons who help us provide the Services, but only as necessary, and they must keep it confidential

  Except only where permitted by applicable laws, we never transfer your personal information to advertisers or marketers without your separate consent

  We do not knowingly collect personal information from children under 13

• The Where

  In line with this Privacy Policy, your information may be processed in Japan, the United States and other countries

• Changes to Privacy Policy

  We may change this Privacy Policy in accordance with the procedures set out below, so please check for any updates

• Other Important Matters

  Measures are taken to safeguard information received from you, and we keep your personal information only as long as necessary

The What

In the course of using our Services, you may provide us, directly and indirectly, with both personal and non-personal information. Personal information is information that can be used to identify you as an individual, such as game username, month of birth, country and region, language, your message to the Services, posting on walls and other forums, game user ID, game data, game crash log data, IP address, access history, OS (version), model of device, IDFA/AAID, Facebook user ID, Facebook username, Apple ID, Google ID, Apple Game Center username, Twitter connecting token/user ID, Twitter screen name, LINE connecting token/username. Non-personal information is information that does not permit direct association with you. Both personal information and non-personal information may be used alone or in the aggregate with information collected from other users. Certain information that appears to be non-personal information may be considered a part of your personal information if it were able to be combined with other identifiers (e.g., combining your zip or postal code with your street address) in a way that enables you to be identified.

The Why

Our primary objective in collecting your information is to provide you with a superior and personally relevant user experience. To achieve this, your information may be used as follows:

- To help us develop, deliver, and improve our Services, including the following aspects of our Services:

• messaging and other communication to and with users
• the creation, updating, accessing, and maintaining of lists of friends or contacts
• transactions for and use of virtual currency and virtual items
• social communication and user-interactive features
• the delivery and targeting of advertising in the Services
• tracking of advertisement fulfillment metrics in the Services
• recommending Services-related products or services of interest directly to you

- To the extent permitted by law, for market research purposes that support our efforts to deliver a more valuable service to our community of users, and to contact you with announcements, newsletters, and promotional materials related to our Services or to offer you opportunities to participate in surveys, contests, or sweepstakes (any of these a "Promotion") via our Services.

- To provide end-user support.

- To prevent and take measures against fraud, illegal activities, infringement of our rights or interests, or breaches of our EULA and this Privacy Policy.

- To send important notices, such as changes to our EULA, this Privacy Policy, or other Services-specific policies. Because this information is important to your interactions with us, you may not opt out of receiving these communications.

- To audit and analyze data for technical administration, to improve our Services, and for end-user communications.

For location-based Services, we may collect, use, and share precise location data, including the real-time geographic location of the device you use to access or use our Services ("Device"). Unless you explicitly opt-in to permit the use and sharing of your personal information regarding your geographic location, your location data will only be collected and used anonymously in a form that does not personally identify you.

The When

Your information is collected by us when you directly interact with our Services and otherwise through use of our Services via your Device.

Your information may also be made available to us when you register with any SNS for use of our Services and/or permit any SNS to share any of your information with us in connection with your use of our Services, including any profile information (such as username, images, date of birth, real name), type of Device, SNS account ID, gender, location information, and your SNS friends' lists, and when any changes are made to that information. By accepting an SNS's applicable terms, you agree and consent to the SNS making such information available to us on those terms.

When you use our Services, we collect information related to your Device as described in "The How" section below. We may also collect information from you when you agree to receive SMS notifications from us concerning events in our games or other software, including the telephone number of your Device.

If you choose to participate in a Promotion, we may request that you provide us with personal information such as your email address or postal address in order to administer your participation in the Promotion.

The How

As already mentioned, we may collect information from you when you directly interact with our Services and otherwise through your access to or use of our Services.

Direct interaction includes such actions as creating a username, providing an email address, creating a friends' list, chatting with other users, or posting to walls and other forums through our Services. It also includes the sending of pre-formatted messages for various purposes such as to challenge friends to beat a high score. You specifically agree that we shall have the right, but not the obligation, to collect and store the information referred to in this paragraph.

We may also collect your information from SNS’s or other third parties who provide it to us, including other users of our Services.

As is standard practice, we do use "cookies" in connection with the Services. A cookie is a small string of text placed on your Device. In addition to strictly necessary cookies that enable us to provide our Services (such those that provide your SNS log-in status when that account ID is linked to functionality on the Services), we may use both performance-gauging and functionality-gauging cookies. Performance-gauging cookies reveal how you use the Services, for instance, which content is the most popular, how much time users are spending there, and what advertising is relevant to you, which helps us provide an optimized experience (we may engage third parties to carry out this analysis, and they may set their own "third party" cookies--see "The Who" for more). Functionality-gauging cookies enables us to remember certain choices you make in interacting with the Services, for instance, any geographic location, language, or fonts you choose, which helps us tailor the Services to your preferences. Neither performance-gauging cookies nor functionality-gauging cookies collect information in any way that personally identifies you.

Except for cookies strictly necessary for enabling us to provide our Services, you have the option to disable cookies stored on your browser by changing the options in your browser to stop accepting cookies or to prompt you before accepting a cookie from the content you visit. Note that local shared objects or "flash cookies", which are different from HTTP cookies, may require different treatment for removal or disablement depending on the version of browser used. If you do not accept cookies, you may not be able to view or use parts of our Services due to limited functionality. Some cookies we use may be stored using a web-browsing component other than a browser application--these cannot be disabled on your Device, but the information collected does not personally identify you, and does not permit tracking between Services.

Some of our Services, including messaging, may use "click-through URLs" linked to other content on our Services. We track this click-through data to help us determine interest in topics, Services usability, and other measures of user engagement.

In using our Services, our servers record information sent from your Device, which may include information such as device type, mobile carrier, unique device identifier ("Device Number"), Internet Protocol ("IP") address, email address, browser type, language, Internet service provider, network status, time zone, geo location, referring and exit pages, time spent, information searched for, time and date stamp, clickstream data, and other statistics on your use of our Services; for some games or other software no Device Number is recorded but in those and other cases we may have access to a generated and non-permanent unique identification number functionally matched with your Device ("Matching Number").

The Who

Our Responsibility for Our Collections

While we will collect and use your information as explained in this Privacy Policy, as a user of our Services you may be permitted to use and create your own profile, connect with other users of our Services, and send messages and transmit information through various channels. Please remember that any communications you have via our Services, depending on, for example, the functionality of the Services used, may reveal information such as any SNS and/or Services profile(s) you create (including your username(s), profile image(s), and profile status/comments, "Profile") and the content of your communications, making this information publicly available to other users. We are not responsible for the activities of other users or other third parties with whom you choose to provide your information or otherwise interact.

Interaction with Other Users via Social Features

As mentioned in "The Why", social interaction is an important part of our Services. You understand and agree that your Profile may be viewable in the Services by other users of the Services and may also be searchable for the purpose of facilitating user-user invitations or other social aspects of the Services. You also understand and agree that certain in-Services achievements/activities of yours may be displayed and viewable in the Services by other users of the Services in connection with social features of the Services. For example, other users of the Services may be able to see your leaderboard ranking, an item you received in a game, or your in-game event history (event ranking, points, etc.). Note that where available you may have the option to change certain aspects of your Profile (e.g., profile image).

Persons with Whom We May Share Your Information

You agree that we may share your information as follows:

• With Third Parties for Industry Analysis and Advertising

You agree that we may share technical information related to your Device (such as IP address), aggregated non-personal information, and anonymous information with advertisers, ad networks, and analytics analysis entities ("Ad Entities") with whom we have strategic relationships, and Ad Entities may also be permitted to collect such information via cookies and other tracking technologies. This information may be used to undertake user trend analyses, demographic profiling, and analytics, and to provide to you tailored and personalized ads and advertising (behavioural advertising). Please note, though, that some Ad Entities also act as Service Providers (defined below) for us, and in those cases we may share your information as explained below.

• With our Service Providers

Sharing of your information may also occur where we engage or employ service providers, vendors, or other third parties to help us provide our Services (each a "Service Provider") (e.g., improvement of our Services' features, promotion and marketing, administration, analytics, customer service, cloud storage, hosting, and other related services), to provide the Services on our behalf, or to assist us in analyzing how our Services are being used. Our Service Providers may have access to your personal information only to perform these tasks on our behalf, and they are obligated not to disclose or use your personal information for any other purpose.

• With Certain Third Parties in Special Circumstances

At times, we may disclose information about you to law enforcement officials or private parties as we believe necessary or appropriate to respond to claims and legal process (including subpoenas), to protect the property and rights of DeNA or a third party, to protect the safety of the public or any person, or to prevent or stop activity we may consider to be, or to pose a risk of being, illegal, unethical, or legally actionable activity.

Under another special set of circumstances, for example, in connection with a merger, acquisition, reorganization, or sale of assets, or in the event of bankruptcy, we may sell or transfer some or all of our assets, and in this connection we may transfer all of your information, including personal information, to any successor entity.

Policy Not to Collect Personal Information from Children

None of our Services is intended for children under the age of 13 ("children") and we do not knowingly collect personal information from, or store personal information of, children. We will upon notice or discovery take all reasonable efforts to erase or destroy any such personal information that may have been collected or stored by us without our knowledge.

The Where

You understand and agree that we may transfer your information to and process it in Japan, the United States and other countries outside of your country of residence. Your consent to this Privacy Policy by accessing or using our Services represents your consent to such transfer and processing.

Changes to Privacy Policy

We reserve the right to change this Privacy Policy at any time. If we change this Privacy Policy in a material way, we will give notice of that in the Services, on our website (https://dena.com/legal/), and/or by email to any email address we may have for you at that time. Your use of our Services after we have changed the Privacy Policy will indicate your consent to the updated Privacy Policy.

Other Important Matters

Push and Local Notifications

Unless you indicated otherwise at installation or chose not to receive push and local notifications where the option is made available to you, you agree that we may send push and local notifications to your Device concerning updates, events, and special offers for our mobile games and other mobile applications of the Services installed on your Device. Please note that where available you may have the option of deactivating push or local notifications by changing the settings of the game/application or of your Device.

Protecting Your Information

We take your privacy very seriously and employ reasonable administrative, physical, and electronic measures to safeguard information received from you and held by us against identity theft and unauthorized access or alteration. In addition, we will take reasonable steps to assure that third parties to whom we transfer any data will provide sufficient protection of your personal information. We do not and will not, at any time, request your credit card information, your username, login password, or any national identification numbers in a non-secure or unsolicited communication (e.g., via e-mail, telephone, or mobile device). We will not keep your personal information any longer than needed for the purpose it was collected or than is necessary for legal or legitimate business purposes.

We will make any legally required disclosures of any breach of the security, confidentiality, or integrity of your unencrypted electronically stored "personal data" or "personal information" (as defined in applicable statutes on security breach notification) to you via email or conspicuous posting on our website in the most expedient time possible and without unreasonable delay, consistent with (i) the legitimate needs of law enforcement; or (ii) any measures necessary to determine the scope of the breach and restore the reasonable integrity of the data system.

Access, Corrections and Certain Opt-Out Options

You may access the personal information we hold about you and to update and/or correct it, subject to certain exceptions. If you wish to access or update your personal information, please contact us in writing. We will not charge any fee for your access request, but may charge an administrative fee for providing a copy of your personal information. In order to protect your personal information we may require identification from you before releasing the information requested.

If you have any concerns with the way we collect and handle your personal information, or would like to correct or request that we delete such personal information held by us, please contact us. We will use commercially reasonable efforts to honor your request; please note, though, that at a minimum we may retain an archived copy of your records as required by law or to send necessary communications to you under this Privacy Policy. You understand that deletion of your personal information may result in you not being able to view or use portions of our Services which depend on such information.

Where you share information with other users through the communication channels of our Services, you generally should not expect to have any ability to modify or remove such communications. Nor should you expect us to modify or delete your comments upon your request.

For a Promotion, you have the option to opt out at any time from participation in such Promotion and the receipt of any related communications by following unsubscribe instructions provided in the relevant communications, or by selecting not to receive communications from us where the relevant media service offers that option.

You may have the option of deleting a Matching Number by performing a dedicated reset or a Device factory reset from the settings of your Device. You understand that by deleting a Matching Number any and all data you had prior to the reset may be lost and irretrievable, and that you may not be able to view or use portions of our Services due to limited functionality.

If you wish to stop receiving SMS messages from us, text "STOP" to the number from which they are sent.

For more information, including possible options you may have, on the use of behavioural advertising by Ad Entities generally, see, e.g., the Digital Advertising Alliance, the Network Advertising Initiative or the Australian Digital Advertising Alliance.

Other Websites and Services

Our Services may contain links to other websites and online services or offers from third parties. For example, our Services may include offers from third party advertisers or the ability to engage in transactions with such entities. If you choose to participate in offer-linked information requests or "click on" an advertisement or another third party link, you may be directed to that third party's website or service and/or be prompted to provide personal information in connection with such activity.

The fact that we link to a third party website or service is not an endorsement or representation of our affiliation with that third party, nor is it an endorsement of such third party's privacy or information security policies or practices or their compliance with any laws. We do not exercise control over third party websites or services, and this Privacy Policy does not apply to information collected by them, including Ad Entities. These other websites or services may place their own cookies or other tracking devices on your computer or mobile device, or collect data or solicit personal information from you. Other websites and services follow different rules regarding the use or disclosure of the personal information you submit to them. We encourage you to read the privacy policies or statements of the other websites and services you use and the terms of the offers in which you participate. You agree that we are not responsible for, nor will we be liable to you or any third party for, your interaction with such third parties or the information requests initiated by such third parties or the subsequent use, treatment, or dissemination of the information you provide to them.

Contacting Us

If you have any questions, inquires, requests, or complaints concerning this Privacy Policy or our information collection practices, please contact us at [email protected] or by post Attn: DeNA Customer Support Center, Shibuya Scramble Square, 2-24-12 Shibuya, Shibuya-ku, Tokyo 150-6140, Japan. We will always try to promptly investigate and resolve the issue with you and the outcomes will be used to assist us to improve the delivery of our Services going forward.

Effective date: 25 May 2018

In this Privacy Policy, "DeNA", "we", "us", or "our" means DeNA Co., Ltd. and its following subsidiaries.

subsidiaries:

• MyAnimeList, LLC., located in the United States

Your privacy is important to DeNA. We designed our Privacy Policy to cover how we collect, use and share your information in connection with use of our multi-region entertainment software, and media dedicated to that software ("Services"). By using our Services, you agree to our collection and use of your information, including your personal information, as described in this Privacy Policy.

So please take a moment to learn the five W's, the How, and other important matters about the information we collect and how we use and share it. If you have any questions, please contact us.

Contents

• The What and the Why
• The types of data we collect from you and which data is used for what purpose
• The When
• When we start using your data and how long we store it
• The How
• How your data are processed and used
• The Who
• With whom we share your data
• The Where
• Where your data will be processed
• Changes to Privacy Policy
• Other Important Matters

The What and the Why

In the course of using our Services, you may provide us, directly and indirectly, with both personal and non-personal information. Personal information is information that can be used to identify you as an individual. Non-personal information is information that does not permit direct association with you. Both personal information and non-personal information may be used alone or in the aggregate with information collected from other users. Certain non-personal information would be considered a part of your personal information if it were combined with other identifiers (e.g., combining your zip or postal code with your street address) in a way that enables you to be identified. But the same pieces of information are considered non-personal information if they are taken alone or combined only with other non-personal information (e.g., your viewing preferences).

Some data is necessary for enabling us to provide the registration to and usage of our Services. This includes the data below.

In addition to the above data, we would also like to use the below data for general advertisement purposes and to inform you of our future offers and similar products.

The When

Direct interaction and use of our Services

Your information is collected by us when you directly interact with our Services and otherwise through use of our Services via your Device (as described in the “How” section below).

Social Plug-ins

・Facebook

- Website: https://www.facebook.com/

- Privacy Policy: https://www.facebook.com/about/privacy/update

・Twitter

- Website: https://twitter.com

- Privacy Policy: https://twitter.com/privacy

・Google+

- Website: https://plus.google.com/about

- Privacy Policy: https://policies.google.com/privacy

Your information may also be made available to us when you register with any SNS for use of our Services and/or permit any SNS to share any of your information with us in connection with your use of our Services, including any profile information (such as username, images, date of birth, real name), type of Device, SNS account ID, gender, location information, and your SNS friends' lists, and when any changes are made to that information. By accepting an SNS's applicable terms, you agree and consent to the SNS making such information available to us on those terms.

Promotion services

If you actively choose to participate in a Promotion, we may request that you provide us with personal information such as your email address or postal address in order to administer your participation in the Promotion.

Duration of Storage

We will not keep your personal information any longer than needed for the purpose it was collected or than is necessary for legal or legitimate business purposes.

The How

As already mentioned, we may collect information from you when you directly interact with our Services and otherwise indirectly through your access to or use of our Services.

Direct interaction

Direct interaction includes such actions as creating a username, providing an email address, creating a friends' list, chatting with other users, or posting to walls and other forums through our Services. It also includes the sending of pre-formatted messages for various purposes such as to challenge friends to beat a high score. We may store the email address of the friend that you choose to email via our Services, but would only do so for social purposes such as generating friend recommendations. You specifically agree that we shall have the right, but not the obligation, to collect and store the information referred to in this paragraph.

Information from Third Parties

We may also collect your information from third parties who provide it to us, including other users of our Services.

Cookies

A cookie is a small string of text placed on your Device. In addition to strictly necessary cookies that enable us to provide our Services (such those that provide your SNS log-in status when that account ID is linked to functionality on the Services), we may use both performance-gauging and functionality-gauging cookies. Performance-gauging cookies reveal how you use the Services, for instance, which content is the most popular, how much time users are spending there, and what advertising is relevant to you, which helps us provide an optimized experience (we may engage third parties to carry out this analysis, and they may set their own "third party" cookies--see "The Who" for more). Functionality-gauging cookies enables us to remember certain choices you make in interacting with the Services, for instance, any geographic location, language, or fonts you choose, which helps us tailor the Services to your preferences. Neither performance-gauging cookies nor functionality-gauging cookies collect information in any way that personally identifies you.

Except for cookies strictly necessary for enabling us to provide our Services, you have the option to disable cookies stored on your browser by changing the options in your browser to stop accepting cookies, or to prompt you before accepting a cookie from the content you visit, or by installing opt-out cookies offered by third parties. Note that "flash cookies", which are different from HTTP cookies, may require different treatment for removal of disablement depending on the version of the browser used. If you do not accept cookies, you may not be able to view or use parts of our Services due to limited functionality. Some cookies we use may be stored using a web-browsing component other than a browser application--these cannot be disabled on your Device, but the information collected does not personally identify you, and does not permit tracking between Services. We may generate and collect Session ID and Browser ID by cookies for the user identification.

“Click-Through URLs”

Some of our Services, including messaging, may use "click-through URLs" linked to other content on our Services. We track this click-through data to help us determine interest in topics, Services usability, and other measures of user engagement.

Recording information from your Device

In using our Services, our servers record information sent from your Device, which may include information such as device type, mobile carrier, unique device identifier ("Device Number"), Internet Protocol ("IP") address, email address, browser type, language, Internet service provider, network status, time zone, geo location, referring and exit pages, time spent, information searched for, time and date stamp, clickstream data, and other statistics on your use of our Services; for some games or other software no Device Number is recorded but in those and other cases we may have access to a generated and non-permanent unique identification number functionally matched with your Device ("Matching Number").

The Who

Our Responsibility for Our Collections

While we will collect and use your information as explained in this Privacy Policy, as a user of our Services you may be permitted to use and create your own profile, connect with other users of our Services, and send messages and transmit information through various channels. Please remember that any communications you have via our Services, depending on, for example, the functionality of the Services used, may reveal information such as any SNS and/or Services profile(s) you create (including your username(s), profile image(s), and profile status/comments, "Profile") and the content of your communications, making this information publicly available to other users. We are not responsible for the activities of other users or other third parties with whom you choose to provide your information or otherwise interact.

Interaction with Other Users via Social Features

As mentioned in "The Why", social interaction is an important part of our Services. You understand and agree that your Profile may be viewable in the Services by other users of the Services and may also be searchable for the purpose of facilitating user-user invitations or other social aspects of the Services. You also understand and agree that certain in-Services achievements/activities of yours may be displayed and viewable in the Services by other users of the Services in connection with social features of the Services. For example, other users of the Services may be able to see your leaderboard ranking, an item you received in a game, or your in-game event history (event ranking, points, etc.). Note that where available you may have the option to change certain aspects of your Profile (e.g., profile image).

Persons and Entities with Whom We May Share Your Information

To the extent you have agreed in the consent form in section “The What” above, we may share your information as follows:

• With Third Parties for Industry Analysis and Advertising

You agree that we may share technical information related to your Device (such as IP address, Matching Number, or Device ID), aggregated non-personal information, and anonymous information with advertisers, ad networks, and analytics analysis entities ("Ad Entities") with whom we have strategic relationships, and Ad Entities may also be permitted to collect such information via cookies and other tracking technologies. This information may be used to undertake user trend analyses, demographic profiling, and analytics, and to provide to you tailored and personalized ads and advertising (behavioural advertising). Please note, though, that some Ad Entities also act as Service Providers (defined below) for us, and in those cases we may share your information as explained below.

Ad Entities

• With our Service Providers

Sharing of your information may also occur where we engage or employ service providers, vendors, or other third parties to help us provide our Services (each a "Service Provider") (e.g., improvement of our Services' features, promotion and marketing, administration, analytics, customer service, cloud storage, hosting, and other related services), to provide the Services on our behalf, or to assist us in analyzing how our Services are being used. Our Service Providers may have access to your personal information only to perform these tasks on our behalf, and they are obligated not to disclose or use your personal information for any other purpose.

• With Certain Third Parties in Special Circumstances

At times, we may disclose information about you to law enforcement officials or private parties as we believe necessary or appropriate to respond to claims and legal process (including subpoenas), to protect the property and rights of DeNA or a third party, to protect the safety of the public or any person, or to prevent or stop activity we may consider to be, or to pose a risk of being, illegal, unethical, or legally actionable activity.

Under another special set of circumstances, for example, in connection with a merger, acquisition, reorganization, or sale of assets, or in the event of bankruptcy, we may sell or transfer some or all of our assets, and in this connection we may transfer all of your information, including personal information, to any successor entity.

Policy Not to Collect Personal Information from Children

None of our Services is intended for children under 13 ("children") and we do not knowingly collect personal information from, or store personal information of, children. We will upon notice or discovery take all reasonable efforts to erase or destroy any such personal information that may have been collected or stored by us without our knowledge.

The Where

You understand and agree that we may transfer your information to and process it outside your country of residence, including in Japan. Your consent to this Privacy Policy by accessing or using our Services represents your consent to such transfer and processing.

The transfer of personal data to recipients outside the EU/EEA is generally prohibited unless:

―the jurisdiction in which the recipient is located is deemed to provide an adequate level of data protection;

―the data exporter puts in place appropriate safeguards (e.g. binding corporate rules; contractual arrangements with the recipient of the personal data, using, for example, the standard contractual clauses approved by the European Commission, adherence to a code of conduct or certification mechanism together with obtaining binding and enforceable commitments from the recipient) or

―a derogation or exemption applies (e.g. where an individual has explicitly consented to the proposed transfer after having been provided with all necessary information about the risks associated with the transfer).

Changes to Privacy Policy

We reserve the right to change this Privacy Policy at any time. If we change this Privacy Policy in a material way, we will give notice of that in the Services, on our website (https://dena.com/legal/), and/or by email to any email address we may have for you at that time. Your use of our Services after we have changed the Privacy Policy will indicate your consent to the updated Privacy Policy.

Other Important Matters

Your Rights

For the exercise of any of your rights mentioned below, please contact us by email at [email protected] or by post at DeNA Customer Support Center, Shibuya Scramble Square, 2-24-12 Shibuya, Shibuya-ku, Tokyo 150-6140, Japan.

Withdrawal of Consent

You can withdraw your consent for the collection, usage and storage of your information and data free of charge and at any time by giving us reasonable notice. Your withdrawal can be sent via mail to [email protected] or by post Attn: DeNA Customer Support Center, Shibuya Scramble Square, 2-24-12 Shibuya, Shibuya-ku, Tokyo 150-6140, Japan.

Upon receiving your request, we will inform you of the likely consequences of the withdrawal of your consent, and will cease to process your information therefrom, unless otherwise permitted or required by applicable laws and regulations. Please note that if you withdraw your consent to any or all usage of your data, depending on the nature of your request, we may not be able to provide to you our Services anymore.

Right of Information, Correction and the Right to be Forgotten

You have the right to request anytime information about the data stored by us concerning you, their source and their recipients as well as the purpose of the data processing. You further have the right of correction, and the right of deletion of the data stored with us anytime.

Right to Object

You have the right to object at any time to processing of personal data concerning yourself which are necessary for the purposes of the legitimate interests pursued by us. We will no longer process the personal data unless there are legitimate grounds for the processing which override the interests, rights and freedoms of you or for the establishment, exercise or defense of legal claims.

Right to Restriction of Processing

You have the right to obtain restriction of procession when:
(a) the accuracy of the personal data is contested by you, for a period enabling us to verify the accuracy of the personal data;
(b) the processing is unlawful and you oppose the erasure of the personal data and request the restriction of their use instead;
(c) we no longer need the personal data for the purposes of the processing, but they are required by you for the establishment, exercise or defense of legal claims;
(d) you have objected to processing your data pending the verification whether the legitimate grounds of us override those of yours.

Right to Data Portability

You have the right to receive the personal data concerning yourself, which you have provided to us, in a structured, commonly used and machine-readable format and have the right to transmit those data to another controller without hindrance from us, where:
(a) the processing is based on consent;
(b) the processing is carried out by automated means

In exercising your right to data portability, you have the right to have the personal data transmitted directly from us to another controller, where technically feasible. The exercise of the right to data portability is without prejudice to the right to erasure.

Right to Lodge a Complaint with the DPA (for EU citizens)

Without prejudice to any other administrative or judicial remedy, you have the right to lodge a complaint with a supervisory authority, in particular in the EU Member State of your habitual residence, place of work or place of the alleged infringement if you are not satisfied with our response or think we are processing your personal data not in accordance with the law.

Opting-out from Promotion

For a Promotion, you have the option to opt out at any time from participation in such Promotion and the receipt of any related communications by following unsubscribe instructions provided in the relevant communications, or by selecting not to receive communications from us where the relevant media service offers that option.

・Adjust

https://www.adjust.com/opt-out/

Deleting a Matching Number

You may have the option of deleting a Matching Number by performing a dedicated reset or a Device factory reset from the settings of your Device. You understand that by deleting a Matching Number any and all data you had prior to the reset may be lost and irretrievable, and that you may not be able to view or use portions of our Services due to limited functionality.

Push and Local Notifications

Unless you indicated otherwise at installation or chose not to receive push and local notifications where the option is made available to you, you agree that we may send push and local notifications to your Device concerning updates, events, and special offers for our mobile games and other mobile applications of the Services installed on your Device. Please note that where available you may have the option of deactivating push or local notifications by changing the settings of the game/application or of your Device.

Protecting Your Information

We take your privacy very seriously and employ reasonable administrative, physical, and electronic measures to safeguard information received from you and held by us against identity theft and unauthorized access or alteration. In addition, we will take reasonable steps to assure that third parties to whom we transfer any data will provide sufficient protection of your personal information. We do not and will not, at any time, request your credit card information, your username, login password, or any national identification numbers in a non-secure or unsolicited communication (e.g., via e-mail, telephone, or mobile device).

We will make any legally required disclosures of any breach of the security, confidentiality, or integrity of your unencrypted electronically stored "personal data" or "personal information" (as defined in applicable statutes on security breach notification) to you via email or conspicuous posting on our website in the most expedient time possible and without unreasonable delay, consistent with (i) the legitimate needs of law enforcement; or (ii) any measures necessary to determine the scope of the breach and restore the reasonable integrity of the data system.

If you have any concerns with the way we collect and handle your personal information, or would like to correct or request that we delete such personal information held by us, please contact us. We will use commercially reasonable efforts to honor your request; please note, though, that at a minimum we may retain an archived copy of your records as required by law or to send necessary communications to you under this Privacy Policy. You understand that deletion of your personal information may result in you not being able to view or use portions of our Services which depend on such information.

If you wish to stop receiving SMS messages from us, text "STOP" to the number from which they are sent.

For more information, including possible options you may have, on the use of behavioural advertising by Ad Entities generally, see, e.g., the Digital Advertising Alliance, the Network Advertising Initiative.

Other Websites and Services

Our Services may contain links to other websites and online services or offers from third parties. For example, our Services may include offers from third party advertisers or the ability to engage in transactions with such entities. If you choose to participate in offer-linked information requests or "click on" an advertisement or another third party link, you may be directed to that third party's website or service and/or be prompted to provide personal information in connection with such activity.

The fact that we link to a third party website or service is not an endorsement or representation of our affiliation with that third party, nor is it an endorsement of such third party's privacy or information security policies or practices or their compliance with any laws. We do not exercise control over third party websites or services, and this Privacy Policy does not apply to information collected by them, including Ad Entities. These other websites or services may place their own cookies or other tracking devices on your computer or mobile device, or collect data or solicit personal information from you. Other websites and services follow different rules regarding the use or disclosure of the personal information you submit to them. We encourage you to read the privacy policies or statements of the other websites and services you use and the terms of the offers in which you participate. You agree that we are not responsible for, nor will we be liable to you or any third party for, your interaction with such third parties or the information requests initiated by such third parties or the subsequent use, treatment, or dissemination of the information you provide to them.

Contacting Us

If you have any questions, inquires, requests, or complaints concerning this Privacy Policy or our information collection practices, or wish to exercise any of your legal rights, please contact us at [email protected] or by post Attn: DeNA Customer Support Center, Shibuya Scramble Square, 2-24-12 Shibuya, Shibuya-ku, Tokyo 150-6140, Japan.

To communicate with our Data Protection Officer, please email to dpo[at]dena.com
*Please replace [at] with @.

© DeNA