Effective Date: June 16th, 2016
Last Updated: July 30th, 2017
We collect several types of personal information from you:
Cygames considers personal information to be any information concerning the personal or material circumstances of an identified or identifiable individual (e.g. name, date of birth, and other information which enables the identification of specific individuals), as well as email addresses, and other information which is associated with an individual. Here are some of the ways in which we may collect personal information on the Services:
- We may collect your email address if you contact us with a question;
- We may collect your email address if you choose to send your link code to us; and
- We may collect your Internet Protocol (IP) address. Your IP address is a number that lets computers attached to the Internet know where to send you data – such as the webpages you view.
Your provision of this information is necessary for us to provide the Services to you. If you do not want us to collect your personal information, please do not provide it to us.
Cookies and Web Beacons
We also use Web Beacons (also known as “clear gifs,” “web bugs” or “pixel tags”) – “Web Beacons” are tiny graphics with a unique identifier, similar in function to cookies, and are used to allow us to count users who have visited certain web pages of the Services and to help determine the effectiveness of promotional or advertising campaigns. When used in HTML-formatted email messages, web beacons can tell the sender whether and when the email has been opened. In contrast to cookies, which are stored on a user’s computer hard drive, web beacons are embedded invisibly on web pages.
Cookies of Third party providers and tracking
A. Linkage with Facebook
The Services use functionality offered by Facebook, Inc. (“Facebook”) which may also collect information under Facebook’s own privacy policies. Hereby, you can link the game data with your Facebook account. To do this, you need to already have a Facebook account or have access to Facebook. Only “public information” on your Facebook profile will be transmitted to us.
Furthermore, the Services use F.O.X., an advertisement tracking tool for smartphone apps provided by CyberZ, Inc.. This tool makes it possible to measure and analyze the effectiveness of smartphone advertising.
The Services also use Everyplay, a tool for game players that combines video sharing with social networking. This tool collects personal information which is provided by the user. Furthermore, the following information is passively collected by Everyplay: device information (digital fingerprint, and various unique identifiers, such as IDFA, Android Ad ID, IDFV and MAC address); IP address; game play activity and actions; usernames and application identifiers ("app id") of some or all of the applications installed on your mobile device; log in information; and player device information (e.g. browser type, language, current screen resolution and app ID of the game installed).
D. Google Analytics
We use Google Analytics, a web analytics service provided by Google, Inc. (“Google”) to gather anonymous statistical and analytical information about how users use our Services to measure audience. For example, Google gathers and aggregates data on page views and clicks on the Services. These analytics are not used to track your journey to other websites or to identify you. The information generated by the Google Analytics cookies about your use of the Services (including your IP address) will be transmitted to and stored by Google on servers in the United States. To opt out of Google Analytics cookies, please visit: http://tools.google.com/dlpage/gaoptout or block these cookies along with other cookies by adjusting the settings of your web browser.
AppsFlyer collects personal information as described below and aggregated information (information about groups or categories of persons, which does not identify and cannot reasonably be used to identify an individual person) to help the app analyze how users use the app. The data collected by the SDK includes information such as IP address, User agent, platform, SDK version, anonymous User ID, time stamp Developer Key, application version, device identifiers such as: IDFA (Identifier For Advertisers), Android ID (Android device), Google Advertiser ID, device model, manufacturer, OS version, in-app events, and network status (WiFi/3G).
F. Red Shell
Red Shell, an advertisement tracking tool provided by Innervate, Inc., may access and collect certain data on the Steam users, including: Steam account identification number, web browser information, operating system version, IP address, installed fonts, and screen resolution. The collected data will be used to monitor and analyze the effectiveness of advertising.
Use of Personal Information
Cygames uses personal information for the purposes prescribed below:
- Delivery of content such as games, video, and music; and the provision of related services;
- Service development, compiling statistics, analysis, questionnaires and other marketing activities intended to improve services;
- Responses to inquiries, consultation, and complaints and the resolution of disputes;
- To provide you special offers, updated information and other new services from Cygames, or other third parties, or to forward promotional materials if you have requested this information or provided your consent for us to do so;
- To complete a transaction or service requested by you;
- To fulfill marketing or promotional purposes;
- To ensure that the Services are relevant to your needs;
- To help us create and publish content that is most relevant to you;
- To allow you access to limited-entry areas of the Services;
- To deliver newsletters or other information that you request;
- To contact you in response to your inquiry; and
- In other manners as disclosed within this policy or at the time of collection.
We will retain your personal information for as long as your account is active or for as long as it is needed to provide you services.
Disclosure to Third Parties
We may share or disclose your personal information with third parties, in particular affiliated companies, in the following instances:
- To fulfill a service to you. For example, if you choose to engage with games or services on the Services, we may share your personal information in order to provide the service to you. Also, if you are entering a sweepstake or contest, we may use your personal information in order to fulfill the terms of that promotion. This means that we may share the information for prize fulfillment purposes including, for example, sharing your postal address with a postal service or mail carriers. We also may share your information with the co-sponsor of that promotion.
- To offer products or services that we believe may be of interest to you or use your personal information for research, administrative and/or internal business purposes. Affiliates, strategic partners, agents, third party marketers or other unaffiliated parties will be handling this. You have the right to ask us not to process your personal data for marketing purposes in accordance with Section 8 of this policy.
- To process and fulfill orders, provide customer service, maintain and analyze data, send customer communications, and collect entries, select winners and fulfill prizes for contests, sweepstakes and other promotions. Delegated third parties, including unaffiliated third-party service providers, agents or independent contractors, such as GREE, Inc., Explay, Inc. and Pole To Win Co., Ltd. providing customer service, who help us maintain our Services and provide other administrative services to us will be handling this. When delegating third parties to handle some or all personal information, Cygames enters into confidentiality agreements and other agreements for the protection of personal information with the delegated parties and requests consent to the terms and agreements thereof so as to safely manage personal information. Third party service providers that help us administer our Services will have access to users’ personal information, if you do not wish for our unaffiliated third party service providers to have access to your information, please do not register or submit any personal information to us.
- To comply with law. We may share personal information when necessary to comply with law or in the good faith belief that such action is necessary in order to comply with the requirements of law, a legally-binding court order or governmental order from an investigation agency or competent regulatory authority that is issued through due process, to protect and defend our rights or property, including the rights and property of Cygames or to act in urgent circumstances when it is necessary to protect the life, body, or property of a person, and the consent of the identified individual is difficult to obtain.
- To third parties as part of any corporate reorganization process including, but not limited to, mergers, acquisitions, and sales of all or substantially all of our assets.
No data transmissions over the Internet can be guaranteed to be 100% secure. Consequently, we cannot ensure or warrant the security of any information you transmit to us and you understand that any information that you transfer to Cygames is done at your own risk. Cygames specifies rules for the protection of personal information, and incorporates appropriate administrative, technical, organizational and physical security measures that are required under applicable regulations. We use firewalls to protect your information from unauthorized access, disclosure, alteration, or destruction. However, please note that this is not a guarantee that such information may not be accessed, disclosed, altered or destroyed by breach of such firewalls and secure server software.
If we learn of a security systems breach we may attempt to notify you electronically so that you can take appropriate protective steps. By using these Services or providing personal information to us, you agree that we can communicate with you electronically regarding security, privacy and administrative issues relating to your use of these Services. We may post a notice on our Services if a security breach occurs. We may also send an email to you at the email address you have provided to us in these circumstances.
Access, Portability & Correction of Personal Information
You have the right to access and to request the correction or portability of the information that we hold about you or to object to the processing of any data relating to you, by using the contact details in Section 21. When Cygames receives a request from you for access to, portability of, correction of, addition to, deletion of or objection to the processing of personal information due to error (hereinafter referred to as Correction), Cygames shall conduct any necessary investigation without delay and provide you or a nominated third party with your personal data or perform a Correction as soon as possible.
Your account information and access to our Services are sometimes accessible only through the use of an individual user ID and password. To protect the confidentiality of personal information, you must keep your password confidential and not disclose it to any other person. Please note that we will never ask you to disclose your password in an unsolicited phone call or email. CYGAMES IS NOT RESPONSIBLE FOR ACTIONS TAKEN REGARDING YOUR ACCOUNT WHILE A USER IS LOGGED IN USING YOUR USER ID AND PASSWORD.
Choice & Opt-outs
We may send you communications or data regarding the Services, including but not limited to (i) notices about your use of the Services, including any notices concerning violations of use, (ii) updates, and (iii) information or materials regarding transactions, products, and/or services that you may have purchased or selected.
You can opt out from receiving any marketing emails at any time by contacting us using the online form (https://www.cygames.co.jp/en/form/policy/).
Discontinuation & Deletion of Personal Information
You have the right to request that we stop processing your personal data and/or delete the information that we hold about you by using the contact details in Section 21. If you request the deletion or erasure of personal information (hereinafter referred to as Discontinuation) because the information allegedly was handled in a manner exceeding the purpose of collection, or was acquired by deceit or other unlawful means, Cygames shall, upon confirming that the person making the request is the identified individual, conduct any necessary investigation without delay and, based on its results, perform Discontinuation free of charge as far as this is possible for Cygames and notify you. However, we may retain a copy of your personal data where we are required or permitted to so by law.
International Transfer of Information
If you choose to provide us with personal information, it will be stored in Japan. Cygames may transfer that information to its affiliates and subsidiaries, across borders, and from your country or jurisdiction to other countries or jurisdictions around the world. If you are visiting the Services from the European Union or other regions with laws governing data collection and use, please note that your personal data is transferred to Japan. Japan does not have the same data protection laws as the EU and will not afford many of the rights conferred upon data subjects in the EU. By providing your personal information you consent to:
- the transfer of your personal information to Japan as indicated above.
Forums, Chat Rooms and Other Public Posting Areas
Please note that any information you include in a message you post to any chat room, forum or other public posting area is available to anyone with Internet access. If you do not want people to know your email address, for example, do not include it in any message you post publicly. PLEASE BE EXTREMELY CAREFUL WHEN DISCLOSING ANY INFORMATION IN CHAT ROOMS, FORUMS AND OTHER PUBLIC POSTING AREAS. WE ARE NOT RESPONSIBLE FOR THE USE BY OTHERS OF THE INFORMATION THAT YOU DISCLOSE IN CHAT ROOMS, FORUMS AND OTHER PUBLIC POSTING AREAS.
We may occasionally send you push notifications through our mobile applications to send you game updates and other service related notifications that may be of importance to you. You may at any time opt out from receiving these types of communications by turning them off at the device level through your settings.
Third Party Services
This statement applies solely to information collected on the Services. The Services may contain links to other web Services. We are not responsible for the privacy practices or the content of these other web Services.
In the event that all or part of our assets are sold or acquired by another party, or in the event of a merger, you grant us the right to assign the personal and non-personal information collected via the Services.
Cygames does not support Do Not Track browser settings and does not currently participate in any “Do Not Track” frameworks that would allow us to respond to signals or other mechanisms from you regarding the collection of your personal information or non-personal information.
Our Policy Regarding Children
We do not knowingly collect or solicit personal information from anyone under the age of 13 or knowingly allow such persons to use the Services. If you are under 13, please do not send any information about yourself to us, including your name, address, telephone number, or email address. No one under the age of 13 may provide any personal information. In the event that we learn that we have collected personal information from a child under age 13, we will delete that information as quickly as possible. If you believe that we might have any information from or about a child under the age of 13, please contact us using the online form (https://www.cygames.co.jp/en/form/policy/).
Right to Complain
If you are not happy with the way in which we are processing your personal data, you have the right to lodge a complaint with your local data protection authority.
The data protection officer in charge is Eitoshi Ashihara.