JP / EN

PRIVACY POLICY

1. Definition of Personal Information

Gadgelab Co., Ltd. understands "personal information" to mean information about a living individual as defined in the Act on the Protection of Personal Information (including name, date of birth, and other information that can identify a specific individual), as well as email addresses and other attribute information relating to an individual that is used in connection with a specific individual.

2. Specifying the Purpose of Use of Personal Information

Gadgelab Co., Ltd. uses personal information to carry out the purposes set out below.

  • To distribute content such as games, video, and music, and to provide services related thereto.
  • To carry out marketing activities such as statistics, analysis, and surveys for the purpose of developing and improving services.
  • To respond to inquiries, consultations, and complaints, and to resolve disputes.

3. Information We Collect

Gadgelab Co., Ltd. may collect the following information in providing the Service.

  • User ID
  • Device information
  • OS and app version
  • Advertising identifiers (IDFA, AAID)
  • Purchase history
  • Play logs (records of use and operation of the game)
  • Crash logs
  • IP address
  • Email address provided when making an inquiry

Gadgelab Co., Ltd. may use third-party analytics, advertising distribution, crash analysis, and similar services for purposes such as analyzing usage of the Service, delivering advertisements, and analyzing defects and failures. The providers of such services may collect, among the information above, device information, advertising identifiers, usage history, crash information, and the like.

4. Restrictions on the Use of Personal Information

Gadgelab Co., Ltd. will not handle personal information beyond the scope necessary to achieve the purpose of use without first obtaining the individual's consent. Even where personal information has been acquired as a result of a merger or other reason, the Company will not handle it beyond the scope of the purpose of use prior to the succession without first obtaining the individual's consent. However, this does not apply in the following cases:

  • Where required by laws and regulations.
  • Where it is necessary to protect the life, body, or property of a person and it is difficult to obtain the individual's consent.
  • Where it is especially necessary to improve public health or to promote the sound upbringing of children and it is difficult to obtain the individual's consent.
  • Where it is necessary to cooperate with a national agency, a local government, or a party entrusted by either in carrying out affairs prescribed by laws and regulations, and obtaining the individual's consent is likely to impede the performance of such affairs.

5. Proper Acquisition of Personal Information

Gadgelab Co., Ltd. acquires personal information by proper means and does not acquire it by deception or other wrongful means. The Company also takes care not to indiscriminately collect information relating to a child under the age of 15 without the consent of a person with parental authority.

6. Notice of the Purpose of Use upon Acquisition of Personal Information

When acquiring personal information, Gadgelab Co., Ltd. will, in advance, notify the individual of the purpose of use or publicly announce it. However, this does not apply in the following cases:

  • Where notifying the individual of, or publicly announcing, the purpose of use is likely to harm the life, body, property, or other rights or interests of the individual or a third party.
  • Where notifying the individual of, or publicly announcing, the purpose of use is likely to harm the rights or legitimate interests of Gadgelab Co., Ltd.
  • Where it is necessary to cooperate with a national agency or a local government in carrying out affairs prescribed by laws and regulations, and notifying the individual of, or publicly announcing, the purpose of use is likely to impede the performance of such affairs.
  • Where the purpose of use is clear in light of the circumstances of acquisition.

7. Changes to the Purpose of Use of Personal Information

When changing the purpose of use of personal information, Gadgelab Co., Ltd. will not make any change beyond the scope reasonably considered to have a substantial relevance to the purpose of use prior to the change, and will notify the individual of, or publicly announce, the changed purpose of use.

8. Security Management of Personal Information and Supervision of Employees

Gadgelab Co., Ltd. establishes personal information protection rules and exercises necessary and appropriate supervision over its employees so as to ensure the security management of personal information, including the prevention of leakage, loss, or damage of personal information.

9. Supervision of Contractors

When entrusting all or part of the handling of personal information to a contractor, Gadgelab Co., Ltd. concludes a contract with the contractor that includes confidentiality obligations, or requires agreement to the terms and conditions established by the Company, and exercises necessary and appropriate supervision over the contractor so as to ensure the security management of personal information.

10. Restrictions on Provision to Third Parties

Gadgelab Co., Ltd. will not provide personal information to a third party without first obtaining the individual's consent, except in the following cases:

  • Where required by laws and regulations.
  • Where it is necessary to protect the life, body, or property of a person and it is difficult to obtain the individual's consent.
  • Where it is especially necessary to improve public health or to promote the sound upbringing of children and it is difficult to obtain the individual's consent.
  • Where it is necessary to cooperate with a national agency, a local government, or a party entrusted by either in carrying out affairs prescribed by laws and regulations, and obtaining the individual's consent is likely to impede the performance of such affairs.
  • Where the following matters have been notified or publicly announced in advance:
    • That the purpose of use includes provision to third parties.
    • The items of data to be provided to third parties.
    • The means or method of provision to third parties.
    • That the provision of personal information to third parties will be discontinued at the request of the individual.

Notwithstanding the preceding paragraph, the parties in the following cases do not fall under the third parties referred to above:

  • Where Gadgelab Co., Ltd. entrusts all or part of the handling of personal information within the scope necessary to achieve the purpose of use.
  • Where personal information is provided in connection with the succession of a business due to a merger or other reason.
  • Where personal information is used jointly with a specific party, and the individual has been notified in advance, or the matter has been placed in a state where the individual can readily ascertain it, of the fact of such joint use, the items of personal information used jointly, the scope of the parties using it jointly, the purpose of use by such parties, and the name of the party responsible for the management of the personal information.

11. Public Announcement of Matters Concerning Personal Information

Gadgelab Co., Ltd. will place the following matters concerning personal information in a state where the individual can ascertain them, or will respond to them without delay at the individual's request:

  • The purpose of use of personal information (excluding matters for which there is no such obligation under the Act on the Protection of Personal Information; if the Company decides not to respond, it will notify the individual to that effect without delay).
  • The contact point for inquiries concerning personal information.

12. Disclosure of Personal Information

When an individual requests the disclosure of personal information, Gadgelab Co., Ltd. will, after confirming that the requesting party is the individual, disclose it without delay. However, where disclosure falls under any of the following cases, the Company may decline to disclose all or part of it, and if it decides not to disclose, it will notify the individual to that effect without delay:

  • Where there is a risk of harming the life, body, property, or other rights or interests of the individual or a third party.
  • Where there is a risk of significantly impeding the proper conduct of the business of Gadgelab Co., Ltd.
  • Where it would violate other laws or regulations.

Information such as access logs, device information, cookies, advertising identifiers, and usage history may, even where it cannot by itself identify a specific individual, be handled as personal information where it can be readily cross-referenced with other information and thereby identify a specific individual. Information that does not constitute personal information will, in principle, not be disclosed.

13. Correction of Personal Information

Where an individual requests the correction, addition, or deletion (hereinafter "correction, etc.") of the content of personal information on the ground that it is not true, Gadgelab Co., Ltd. will, except where a special procedure is prescribed by other laws or regulations, conduct the necessary investigation without delay within the scope necessary to achieve the purpose of use, make the correction, etc. of the content of the personal information based on the results, and notify the individual to that effect.

14. Suspension of Use of Personal Information

Where an individual requests the suspension of use or erasure (hereinafter "suspension of use, etc.") of their personal information on the ground that it is being handled beyond the scope of the purpose of use announced in advance, or that it was acquired by deception or other wrongful means, Gadgelab Co., Ltd. will, after confirming that the requesting party is the individual, conduct the necessary investigation without delay, carry out the suspension of use, etc. of the personal information based on the results, and notify the individual to that effect. However, where the suspension of use, etc. of the personal information requires a large expense or is otherwise difficult to carry out, and where it is possible to take alternative measures necessary to protect the rights and interests of the individual, the Company will take such alternative measures.

15. Deletion of Account and Data

Users can delete their account and data at any time by performing account deletion in the game.

16. Contact Point for Inquiries

For inquiries concerning the handling of personal information, or for requests for disclosure, etc., please contact the point of contact below.

Gadgelab Co., Ltd. — Personal Information Inquiry Desk
Email:

17. Governing Language

The Japanese text of this Policy shall be the authoritative original. Even if a translation into English or any other language is prepared for reference, in the event of any discrepancy between the Japanese version and a translated version, the Japanese version shall prevail.

Established on October 23, 2024.