Privacy policy for personal data subject to GDPR

1. Introduction

 NTT Solmare Corporation (the “Company”) provides services to customers in many countries. When you use our services, we will acquire, use and store your information. This Privacy Policy established by the Company specifies the purposes of acquiring your personal data by the Company to enable you to understand your rights with respect to such personal data.

 Please ensure to read through this Privacy Policy since you need to give your consent and accept the Terms of Use of the relevant service in order to use the Company’s services.

2. Personal Data to be Acquired and Its Intended Use

 The Company will acquire the personal data listed below. The personal data to be acquired by the Company will include the information directly provided by you and the information pertaining to your use of the services.

 The Company will use such information for performance of contracts or for the purposes specified below, based on your consent.

  1. Information necessary for providing game content
     The Company will acquire and use the following information for providing the game content:
    a. Information concerning telecommunication devices, and information acquired through cookies and other means
     When you use the relevant apps and/or services, we may automatically acquire information on the mobile phone device, tablet, PC and other telecommunication devices you used and also through cookies and other means.
     - Information on equipment identification of telecommunication device (device token, register ID, etc.)
     - IP address, device name, OS information, browser version, etc. of the telecommunication device
     - Information related to crashing of the relevant app (device identifier for crash analysis and crash log data)
     - Information related to the progress of the game (progress status, billing status, etc.)
    b. Information on login authentication
     When you install the relevant app, it will automatically generate your authentication ID. This authentication ID will be the key for storing and updating your game data and is required for your game to progress.
    c. Information on passing and linking of the data
     In order to allow the relevant service to be used on more than one device, you need to provide us with your Facebook account, or Google ID or Apple game center ID.
     Such account and ID information will be used to certify that the owner of those devices is the same person and to synchronize the user data including progress. Meanwhile, the Company will acquire no content or information linked to such account and ID information (e.g., user profile information and information on use of services not related to the relevant service).
    d. Information used within the game and exchanged with other users
     Your user name used within the game you registered and the communication exchanged with other users in the game will be stored. While the user name you specified is information necessary for progress of the game since it is reflected in the scenario within the game, you can change it at any time.
  2. Information necessary for advertising and marketing purposes
     The Company will acquire and use the following information for the purpose of advertising and marketing:
     - Advertising identifier of the telecommunication device (IDFA, AAID)
     - Information on equipment identification of telecommunication device (device ID)
     - Device name, OS information, browser version, etc. of the telecommunication device
     - Location information (country, city, town, zip code, etc.)
     - In-store search word, advertising information from transition source (e.g., date and time of transition from advertisement to the store)
     Out of those, you can reset the advertising identifier yourself by setting your device. For putting restrictions on the advertisements which use IDFA, see Apple Inc.’s website ( For putting restrictions on the advertisements which use AAID, see Google LLC’s website (
  3. Information necessary for responding to inquiries
     The Company receives and stores the information you provided to the Company through e-mails (e.g., e-mail address and name).
     In addition, when you contact the Company through an inquiry form within the relevant service, the Company will acquire and use the following information in order to respond to your inquiry, demand, complaint and other requests in a proper manner:
     - Player ID
     - Name of country/region
     - Device information (OS and device name)
     - History of billing for the relevant service within app (receipt information)
     We may also request you to separately provide the screen shot and other materials when the service is used for the purpose of investigation and resolution of your issue.
  4. Participation in surveys
     For the following information which is to be handled by the Company as a result of your participation in a survey and other studies conducted by the Company, your entry for a prize competition or enrollment in a membership program (“Participation in Surveys”), the Company will acquire and use it to the extent it is necessary for sending the materials needed for the survey and other studies and a reward for participation in the survey and other studies, sending competition prizes, improving the quality of services, developing new services and introducing the Company’s content distribution and other services.
     - Your name, address, phone number, e-mail address, age, date of birth, occupation, gender, etc. provided in participating in a survey and other studies
     - Any other items falling under the category of personal information among those provided with your participation in surveys
  5. Entrusted business
     For the personal information which is to be handled by the Company in performing the services entrusted by other entities to the Company (distribution, sale on commission, investigation, etc. of products and services of other entities), the Company will acquire and use it to the extent it is necessary for performing the entrusted services.
  6. Provision of your personal data to third parties
     The Company may provide a third party with your personal data in accordance with the provisions of the Company’s contractual terms and conditions and applicable laws.

3. Customer’s Choice

 Provision of your personal data to the Company will be made upon your consent in principle. If any information necessary for provision of the game content is not provided, the relevant service will not work and the service will not be available for use. In addition, when you put restrictions on advertisements using advertising identifiers, the number of advertisements may not change; however, the relevance of advertisements may become lower than before. In order to withdraw your consent after accepting this Policy, please uninstall the app.

4. Cases Where Parental Consent is Required

 The Company will not intentionally collect any personal data from customers under the age of 16 (or other age specified by applicable laws) without obtaining parental consent or unless permitted by the applicable laws. If you are under the age of 16 (or other age specified by applicable laws) and intend to use the Company’s services, you need to check the laws applicable to you to see whether such services may be used without the consent of your parents.

5. Retention Period

 The Company will retain your personal data for as long as it is needed for providing you with the relevant service and will erase it promptly when it becomes no longer necessary.

6. Security and Transfer to Other Countries

 As needed to provide its services, the Company may, in addition to transferring the customer data to Japan, outsource its handling of the customer data to a subcontractor and other third parties. Such subcontractors include companies having the billing capacity for the relevant service, companies providing customer support services, cloud storage companies, and companies providing advertising/marketing analysis tools, etc. Those third parties include entities outside Japan and it may be possible that they transfer your personal data to a country without personal data protection legislation equivalent to that of the country you live in. In such case, the Company will take any appropriate measures required to protect your personal data in accordance with the requirements of applicable laws and regulations.

 The Company complies with the applicable laws and regulations in order to prevent any unauthorized access to or disclosure of your personal data, to maintain the correctness of the personal data, and to dispose of it properly when necessary, and is committed to handling the personal data at a high level of information security. The Company encodes the communication when acquiring or transferring the personal data and puts limitations on the access privileges for the personal data stored, which is handled only by the individuals having a need in performing the duties. In addition, the Company makes a periodic review to ensure that the aforementioned efforts are made effectively and adequately and are made at a proper level.

7. Disclosing Your Personal Data

 If you intend to exercise your relevant rights in connection with your personal data (including the rights of access, correction, removal, limitation, data portability, and objection) pursuant to the laws applicable to you, please contact us at

8. Amendment to this Privacy Policy

 The Company may amend this Privacy Policy on as needed basis in order to respond to amendments to the laws and regulations or in accordance with business needs. When making such amendment, you will be notified of it through the relevant service or communication on our website.

9. Objection

 If you believe that the Company’s data processing infringes the applicable laws, you may lodge a complaint with the supervisory authority for data protection in your country pursuant to the laws of your country.

10. Inquiries

 Any questions or concerns about this Privacy Policy or handling of customer data should be addressed to:

 NTT Solmare Corporation

 Sumitomo Building No. 2, 4-7-28 Kitahama Chuo-ku, Osaka 541-0041, Japan

 Note that, depending on the details of your inquiry, you may be requested to submit additional information so that we can address the issue in a proper manner.

November, 2018

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