DeNA West Privacy Policy

Last Updated: April 11, 2017

As used in this Privacy Policy, "DeNA West", "we", "us", or "our" refer to ngmoco, LLC, and all of its subsidiaries.

Your privacy is important to DeNA West. We designed our Privacy Policy to cover how we collect, use, disclose, transfer and store your information. Please familiarize yourself with our privacy practices and let us know if you have any questions.

Our Privacy Policy applies only to the collection, use and disclosure of personal information that is provided to us in your use of: (i) our applications for mobile platforms or devices and our web applications accessible on third party social networking services ("SNS") (our mobile and web applications, collectively, "DeNA West Applications"), (ii) our game publisher networks and crowd sourcing services ("Networks") provided in connection with DeNA West Applications and Third-Party Mobile Applications (defined below), (iii) our portal for third-party publishers ("Developer Portal"), (iv) our web domains and subdomains, including ngmoco.com, plusplus.com and mobage.com (collectively, our "Sites"), and web forums or messaging boards in DeNA West Applications and our Sites (collectively, our "Forums"). Any and all of our DeNA West Applications, Networks, Developer Portal, Sites and Forums, collectively, our "Services".

We reserve the right to update this Privacy Policy at any time. If we modify this Privacy Policy in a material way, a notice will be posted in our Services and on the Sites along with the updated Privacy Policy. We will also update the "Last Updated" in the Privacy Policy. By continuing to access the Services after we have posted an updated Privacy Policy or have provided you with notice of a modification, you are indicating that you agree to be bound by the modified Privacy Policy. If the modified Privacy Policy is not acceptable to you, your only recourse is to cease using the Services.

Please visit this page periodically to remain up-to-date as to any Privacy Policy changes. Take a moment now to read the following to learn about our information collection practices that may impact you as a user with access to our Services ("DeNA West User"). For information regarding the collection and use of Personal Information (defined below) from children under 13 years old, see the Section below, entitled "Our Policy Toward Children".

We Collect Personal Information and Non-Identifying Information

In the course of using our Services, we may be provided with certain personally identifiable information that can be used to contact or identify you. Personally identifiable information may include, but is not limited to, your name, phone number, photo representation ("avatar"), email address and mailing address ("Personal Information"). We will collect, use, transfer and disclose Personal Information in accordance with our Privacy Policy.

We also collect non-personal information, which is data in a form that does not permit direct association with you or any specific individual ("Non-Identifying Information"). Non-Identifying Information is aggregated and used to help improve our Services and Third Party Mobile Applications by providing a better way to understand the DeNA West User experience with the level of interest in various portions of our Sites, specific DeNA West Applications or specific Third-Party Mobile Applications. We may collect, use, transfer and disclose Non-Identifying Information for any purpose; details provided in this Privacy Policy about what Non-Identifying Information we collect currently, and how we use, transfer and disclose such Non-Identifying Information concern only how such information is collected and used today.

Both Personal Information or Non-Identifying Information may be used alone or in the aggregate with information collected from other DeNA West Users. Our primary objective in collecting any Personal Information or Non-Identifying Information is to provide you with a superior and personally relevant user experience.

How we use your Personal Information

Your Personal Information may be used, for instance:

· To help us to develop, deliver, and improve our Services and advertising;

· To recommend products of interest directly to you;

· For market research purposes that support our efforts to deliver a more valuable service to our community of DeNA West Users;

· For example, we may use your Personal Information 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.

· If you decide at any time that you no longer wish to receive such communications from us, please follow the unsubscribe instructions provided in any of the communications. (See "Changing or Removing Information" below for further information.)

· To allow us to keep you posted regarding our latest Service announcements, software updates, and upcoming events;

· To send important notices, such as communications about your purchases and changes to our Terms of Use, this Privacy Policy, or other Service-specific policies. Because this information is important to your interactions with DeNA West, you may not opt out of receiving these communications; and

· To audit and analyze data to improve our Services and customer communications.

When We Collect Information

In connection with DeNA West Users accessing our Services, we may collect Personal Information which might include your email address, as well as information on mobile device type, mobile carrier, a mobile device identifier ("Device ID"), Internet Protocol ("IP") address and geo location, as applicable. We may use a Device ID to make it possible to authenticate and understand your use of our Services, or any third-party application utilizing our Services (“Third Party Mobile Application”) that you may choose to access through our Services.

Related to this information collection, our Services may serve ads that contain links to other mobile applications, and we may utilize a Device ID to track clicks or other ad fulfillment metrics. Our use of a Device ID does not enable us to identify you personally, and we do not store this information in connection with your DeNA West Account (see Terms of Use) information.

If you are a third-party publisher, you can register to develop Third Party Mobile Applications via our Sites (on registration, each a “Third Party Publisher”). In connection with registration as a Third Party Publisher, we may collect your name, mailing address, email address and telephone number and other information relevant to the Developer Portal and publication of Third Party Mobile Applications, including bank account and taxation information for vendor registration. We collect this Personal Information to ensure that we are able to contact you and for purposes of operation of the Developer Portal and publication of your Third Party Mobile Applications.

You may also provide Personal Information or Non-Identifying Information anytime that you are in contact with DeNA West or a DeNA West-affiliated company. If your Personal Information or Non-Identifying Information is shared with our affiliates, such sharing will be in accordance with this Privacy Policy.

Other instances when Personal Information may be collected via our Services include the following:

If you choose to link your DeNA West Account to an SNS (including by logging in to our Services via SNS), Personal Information that you independently submit to an SNS (e.g., Facebook) may be collected and used by us in order to provide you with enhanced functionality. In these instances, you consent to DeNA West’s access and use of your username, alias and any other Personal Information you have independently provided to and made accessible through the SNS. Such access will be in accordance with the privacy settings you have set in your SNS account, if any. Similarly, we may use Personal Information that you have provided to us to help you establish social connections with other DeNA West Users.

If you choose to participate in a Promotion, We may request that you provide us with Personal Information such as your email address or mailing address in order to administer your participation in the Promotion.

In connection with use of our Services or Third-Party Mobile Applications, in addition to information on device type, mobile carrier, IP address, platform version, and geo-location, as applicable, we may also collect navigation, interaction and engagement information regarding DeNA West Users.

Certain Non-Identifying Information would be considered a part of your Personal Information if it were combined with other identifiers (e.g., combining your zip code with your street address) in a way that enables you to be identified. But the same pieces of information are considered Non-Identifying Information when they are taken alone or combined only with other Non-Identifying Information (e.g., your viewing preferences).

Please note that to the extent any Third-Party Mobile Application collects any Personal Information separate from the operation of any DeNA West Services then the collection, use and disclosure of that information is under the terms of any applicable privacy policy, terms of service or the like made available by the owner/operator of that Third-Party Mobile Application.

Cookies & Other Technologies

As is standard practice, we use "cookies" to help us study traffic patterns and understand the effectiveness of our marketing communications. A cookie is a small string of text that we send to your computer’s or mobile device's browser. Other types of cookies exist, but the cookies we use in connection with our Services are only used to obtain browser-specific information. For example, we do not use cookies to retrieve data from your hard drive, pass on computer viruses, or capture your email address. Cookies we use can reveal, for instance, which pages are the most popular, how much time DeNA West Users are spending there, and how they are interacting with the content on such pages.

You have the option to disable cookies by changing the options in your browser to stop accepting cookies or to prompt you before accepting a cookie from the pages you visit. If you do not accept cookies, however, you may not be able to view or use all portions of our Services due to limited functionality.

Some of our Services, including email messaging, 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 DeNA West User engagement.

We may also use "pixel tags," "web beacons," "clear GIFs" or similar means (individually or collectively "Pixel Tags") in connection with our Services and to collect usage, demographic and geographical location data. A Pixel Tag is an electronic image, often a single pixel that is ordinarily not visible to users and may be associated with cookies on a user’s hard drive. Pixel Tags allow us to count users who have visited certain pages of the Sites, to deliver branded services and to help determine the effectiveness of promotional or advertising campaigns.

When you use our Services or Third-Party Mobile Applications, our servers automatically record information that your browser or the applicable Service or Third-Party Mobile Application sends ("Log Data"). This Log Data may include information such as your computer’s or mobile device’s IP address, browser type, language, Internet Service Provider (ISP), referring and exit pages, time spent, information searched for, time and date stamp, clickstream data and other statistics. We use this information to monitor, analyze and understand trends, for technical administration of Services and Third-Party Mobile Applications, and to gather demographic information about our DeNA West User base as a whole. We, and Third Party Publishers may use this information for product and services improvements, and in marketing and advertising services.

BY CLICKING ON THE "SIGN UP" BUTTON, WHERE APPLICABLE, OR OTHERWISE BY ACCESSING OR USING OUR SERVICES YOU ARE CONSENTING TO THE USE OF COOKIES AND OTHER TRACKING TECHNOLOGIES ON YOUR DEVICE.

When We Disclose Your Information Within DeNA West Services

As a DeNA West User, you may create your own profile, connect with other users of the Services, 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 any DeNA West Application or Third-Party Mobile Application connected to our Services, may reveal the content of your communications, making this information publicly available to other users. DeNA West is not responsible for the activities of other users or other third parties with whom you choose to provide your Personal Information or otherwise interact.

Note also 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 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 certain 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.). Where available you may have the option to change certain aspects of your profile.

With Third Parties for Industry Analysis

In addition to sharing aggregated Non-Identifying Information with Third Party Publishers, we may also share aggregated Non-Identifying Information with advertisers and ad networks ("Advertising Entities") with whom we have strategic relationships. Unless you specifically opt in to share your Personal Information, the information that we share with these third parties will only be used in the form of Non-Identifying Information to support user trend analyses and demographic profiling. Some Third Party Publishers and Advertising Entities also act as Service Providers (defined below) to us, so in those cases we will share your information as described below.

With Preferred Partners

We may share your username, email address and Device ID (collectively, "Specific Shared Data") with certain of our Third Party Publishers and other business partners ("Preferred Partners") for those parties to assist us with providing you with the aspect of the Services for which you provided such Specific Shared Data to us, and to use such Specific Shared Data to provide you with information and marketing materials about Third Party Mobile Applications and other products and services in order, for example, to further enhance your use of our Services and to augment your gaming and social networking experience generally. In addition, in the event of a user inquiry concerning Third Party Publishers or Third Party Applications, we may send Specific Shared Data as well as the inquiry to a Preferred Partner to address the inquiry.

We only share such information with Preferred Partners pursuant to an agreement by which the Preferred Partner is under obligations not to disclose or use it for any other purpose. You may contact us by any of the means provided in the "Contacting Us" section below to request not to have such information provided to Preferred Partners, understanding, however, that if such information is not shared with Preferred Partners it may affect your ability to use or access portions of the Services.

Some Preferred Partners also act as Service Providers (defined below) to us, and in those cases we may also share Personal Information and Non-Identifying Information as described below.

With Third Party Social Networking Services (SNSs)

You may link your DeNA West Account information with certain SNSs where other DeNA West Users have existing SNS accounts. In these instances, with your permission and on your behalf, we will share your email address and screen name or alias with the applicable SNS. Through use of such services’ application programming interfaces (APIs) we can receive certain information (which may include your Personal Information) in accordance with the privacy settings you have set in your SNS account, if any.

Other than what we may share with the SNS in connection with such linking, the personal information an SNS has about you is obtained by the SNS independent of our Services. Other 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 services you use.

With our Service Providers

Disclosure of your Personal Information and Non-Identifying Information may also occur where we engage or employ service providers, vendors or other third party entities to facilitate provision of our Services (each a "Service Provider") (e.g., without limitation, improvement of our Services’ features, user account authentication, promotion and marketing, administration, analytics, virtual currency transactions, crowd-sourcing, cloud storage 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 are obligated not to disclose or use it for any other purpose.

Under Special Circumstances

At times, we may disclose information about you to law enforcement officials or private parties as we, in our sole discretion, believe necessary or appropriate to respond to claims and legal process (including but not limited to subpoenas), to protect the property and rights of DeNA West 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, any 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, transfer or otherwise share some or all of DeNA West assets, including your Personal Information.

Our Policy Toward Children

Except only for Limited Plus Account (see Terms of Use) access, our Services are not intended for children under the age of 13 ("children") and we do not knowingly collect any Personal Information from children. If we discover that we have inadvertently collected Personal Information from children, we will take all reasonable measures to erase such information from our systems and records as soon as possible.

Location-Based Services

For location-based Services, we may collect, use, and share precise location data, including the real-time geographic location of your computer or mobile 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. When you opt in to Third Party Mobile Application providers’ location services, we will share your geographic location with such Third Party Mobile Application providers in connection with their location services. Please note that some location-based services may require your Personal Information for the feature to work as intended.

Invite-A-Friend

If you choose to use our referral services to tell a friend about our Services, we will ask you for your friend’s name and email address. We will automatically send your friend a one-time email inviting him or her to use an aspect of our Services. DeNA West hashes these email addresses after using them for the sole purpose of sending this one-time email.

Find-A-Friend

DeNA West Users can access the find our find-a-friend feature. We present DeNA West Users with options to search for a friend or group of friends. Options include, but are not limited to, searching one of our Networks, scanning the DeNA West User’s mobile device, and scanning the DeNA West User’s Facebook, Google or Yahoo! contacts. The DeNA West User may either add an existing DeNA West User, or invite a friend to join the Services through the third-party service. To facilitate, DeNA West will provide interfaces to authenticate to such third-party service. We do not store the DeNA West User’s login credentials. The DeNA West User who uses this feature is bound by the terms of the third-party service.

Emailing Via a DeNA West Application

DeNA West Users may send pre-formatted messages through use of their personal email account connected to their mobile device to, for example, challenge their friends to beat their high score in an DeNA West Application where this functionality is available. DeNA West 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 (e.g., in connection with "people you may know" functionality). The message you initiate will be sent through your personal email account to the email addresses you choose.

How We Protect Your Personal Information

DeNA West takes your privacy very seriously and employs administrative, physical and electronic measures to safeguard your information from identity theft and unauthorized access. We do not and will not, at any time, request your credit card information, your account ID, login password or national identification numbers in a non-secure or unsolicited communication (e.g. via e-mail, telephone, 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" (as defined in applicable state statutes on security breach notification) to you via email or conspicuous posting on the Sites in the most expedient time possible and without unreasonable delay, insofar as 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.

Changing or Removing Information

As applicable, you may update or delete the Personal Information in your profile by accessing your DeNA West Account. You may also email us at dena_corp_info@dena.com to request that we delete your Personal Information from our database. We will use commercially reasonable efforts to honor your request. We may retain an archived copy of your records as required by law or for legitimate business purposes. Specific Shared Data cannot be retrieved from Preferred Partners after its disclosure.

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.

If you participate in a Promotion hosted by us (where you may or may not disclose the information requested), you have the option to opt out at any time from such participation and the receipt of any related communications. Please follow the unsubscribe instructions provided in the relevant communications.

If your friend received an invitation from DeNA West per your referral to try the Services, your friend may request that the name and email address used in the invitation be removed from DeNA West’s records. We store this information for the sole purposes of measuring the effectiveness of our referral program and sending the email you initiated, but your friend can request to have it removed from our database by emailing us at dena_corp_info@dena.com.

Links to 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 a DeNA West User chooses to participate in offer-linked information requests or "clicks on" an advertisement or another third party link, such DeNA West User 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 laws. We do not exercise control over third party websites or services. These other websites or services may place their own cookies or other files on your computer or mobile devices, 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 DeNA West is not responsible for, nor will it 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 voluntarily choose to provide to them.

Non-US Users

Information that you provide may be transferred or accessed by entities around the world as described in this Privacy Policy. If you are located outside the United States, you understand that we transfer Personal Information to and process it in the United States. Your consent to this Privacy Policy followed by your submission of Personal Information represents your agreement to that transfer.

DeNA West abides by the safe harbor framework ("Safe Harbor") developed by the US Department of Commerce and the European Union and Switzerland regarding the collection, use, and retention of personal information from individuals who reside in the European Union and Switzerland. As detailed in this Privacy Policy, we specifically agree to comply with each of the seven Safe Harbor privacy principles for the European Union and Switzerland: Notice, Choice, Onward Transfer (Transfers to Third Parties), Security, Data Integrity, Access and Enforcement.

Individuals who wish to file a complaint or who take issue with our Safe Harbor policies should direct such communication to us as specified in the Contacting Us section below. If you are sending us a privacy-related complaint, please provide it in English because this will help expedite the process. We will investigate and attempt to resolve complaints regarding use and disclosure of personal information in accordance with the principles contained in this Privacy Policy. For complaints that cannot be resolved between DeNA West and a complainant, we commit to cooperate with data protection authorities located in the European Union, the Swiss Federal Data Protection and Information Commissioner, or their authorized representatives to resolve such disputes.

Your California Privacy Rights

California Civil Code Section 1798.83 permits customers of DeNA West who are California residents to request certain information regarding our disclosure of personal information to third parties for their direct marketing purposes. If you are a California resident and have provided DeNA West with personal information within the last year, you may make such a request by emailing us at the following email address with the email’s subject titled as "California Privacy Rights": dena_corp_info@dena.com.

If you are under 18 and resident in California, you may request and obtain removal of content or information posted by you on our Services as a registered user of our Services. You may request removal by providing us via this form with (i) the email address or user name associated with your registration; and (ii) a description sufficient to identify and locate each item of content and/or information posted on our Services by you as a registered user of our Services that you wish removed. Please note that as permitted or required by applicable law, removal does not ensure complete or comprehensive removal of the content or information posted on our Services by you as a registered user.

Within thirty (30) calendar days of receiving such a request, we will provide a list of the categories of personal information disclosed to third parties for such third parties’ direct marketing purposes during the immediately preceding calendar year, along with the names and addresses of these third parties. A request may be made no more than once per calendar year and we are not required to respond to requests made by means other than through the email address above.

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 "When We Collect Information" and "Cookies & Other Technologies", above), and this cannot be disabled by "do not track" or other mechanisms available on your mobile Device’s browser.

Language

The controlling language of this Privacy Policy is English; any provided translation of this Privacy Policy is for purposes of convenience only and the English version shall govern to the extent of any inconsistency.

Contacting Us

If you have any questions, inquiries, requests or complaints concerning our Privacy Policy or information practices, please contact us at dena_corp_info@dena.com, by phone at 415-375-3170 or by regular mail attn: Privacy Officer, DeNA Corp. 665 3rd Street, Suite 150, San Francisco, CA 94107.

Privacy Policy (for the users in EU/EEA)

Effective date: May 25, 2018

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

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

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.

Item Type of Data Purpose of use
Basic information
  • E-mail address
  • Language
To help us develop, deliver, and improve our Services, including the following aspects of our Services:
  • transactions for and use of virtual currency and virtual items
  • providing end-user support.
IP address
  • IP address
Cookies
  • Cookies
Data about your account and use of services
  • Game user ID
  • Game username (nickname)
  • Game data
  • Gameplay related activities information (including payment amount)
  • Game crash log data
  • Your message to the Services
Information from Third Parties
  • Facebook user ID
  • Facebook username
  • Google ID
  • Apple Game Center username
Basic information
  • E-mail address
  • Language
To prevent and take measures against fraud, illegal activities, infringement of our rights or interests, or breaches of our Terms of Use and this Privacy Policy.
IP address
  • IP address
Cookies
  • Cookies
Data about your account and use of services
  • Game user ID
  • Game username (nickname)
  • Password
  • Game data
  • Game play related activities information (including payment amount)
  • Your message to the Services
Information from Third Parties
  • Google ID
  • Apple Game Center username
Basic information
  • E-mail address
  • Language
To audit and analyze data for technical administration, to improve our Services, and for end-user communications.
IP address
  • IP address
Cookies
  • Cookies
Data about your account and use of services
  • Game user ID
  • Game username (nickname)
  • Game data
  • Game play related activities information (including payment amount)
Information from Third Parties
  • Facebook user ID
  • Facebook username
  • Google ID
  • Apple Game Center username

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

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 login 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.

“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, 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.

  • 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 any 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, 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 dena@opencs.dena.jp or by post at DeNA Customer Support Center, Shibuya Hikarie, 2-21-1 Shibuya, Shibuya-ku, Tokyo 150-8510.

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 dena@opencs.dena.jp or by post Attn: DeNA Customer Support Center, Shibuya Hikarie, 2-21-1 Shibuya, Shibuya-ku, Tokyo 150-8510 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.

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 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, inquiries, 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 dena_corp_info@dena.com, by phone at 415-375-3170 or by regular mail attn: Privacy Officer, DeNA Corp. 665 3rd Street, Suite 150, San Francisco, CA 94107.

To communicate with our Data Protection Officer, please email to dpo@dena.com.