Last Updated: April 15, 2022

This Privacy Policy explains how information about you is collected, used and disclosed by ZIGZAGAME Inc., （Address: NT Building 11F, 1-47-1, Oi, Shinagawa-ku, Tokyo, Japan. Representative Director: Yoshiya Nagatomi）(“ZIGZA”, “us”, “we” or “our”) when you use our websites, games, mobile applications and other online products and services that contain this policy (collectively, the “Services”) or when you otherwise interact with us. ZIGZA is the data controller of your personal information for purposes of the EU General Data Protection Regulations (GDPR).

We may change this Privacy Policy from time to time without any prior notice. If we make changes, we will notify you by revising the date at the top of the Privacy Policy and, in some cases, we may provide you with additional notice (such as by adding a statement to the homepage of our Services or sending you a notification). If you do not agree to the changes, please do not use our Services or otherwise do not provide us with your personal information. We encourage you to review the Privacy Policy whenever you access the Services to stay informed and updated about our personal information practices and the ways you can take appropriate steps to protect your privacy.

I. Collection of Personal Information

Information You Provide to Us

We collect information you provide directly to us via your access or use of the Services. For example, we collect your personal information you provided when you create an account, interact with other users, request customer support, sign up to receive newsletters, participate in surveys or otherwise communicate with us. The types of information we may collect include your username, password, email address and any other information you choose to provide.

Further, we may collect the personal information which includes an individual number known as My Number (“Specific Personal Information”) from winners of cash awards and/or prizes. Please see Section II. below for a purpose of use of such Specific Personal Information.

Information We Collect Automatically When You Use the Services

When you access or use our Services, in addition to information that you provide directly to us, we also automatically collect certain other information about you, including:

• Usage Information: We collect information about your use of our Services, including gaming service ID, levels completed, game scores, time spent using our Services, and other game play information.
• Log Information: We log information about your use of our Services, including your browser type and language, access times, pages viewed, your IP address and the website you visited before navigating to our Services.
• Hardware Information: We collect information about the computer or device you use to access our Services, including the hardware model, operating system and version, browser mobile network information, list of other ZIGZA mobile applications installed on the device, MAC address, IP address, International Mobile Equipment Identity (“IMEI”) number and other unique device identifiers made available by the operating system of your device.
• Location Information: We may collect information regarding the geographic location of your device each time you use the Services as provided on iOS or Android platforms, to the extent the setting on your device allowed such geographical location information to be collected. You may opt-out of such collection of your geographic location information by changing the settings on your device. Your location information is stored for the period specified in the Services before collection.
• Information Collected by Cookies and Other Tracking Technologies: We use various technologies to collect information about your experience with the Services, and this may include sending cookies to your computer or mobile device. “Cookies” are small data files stored on your computer hard drive or in device memory that help us to improve our Services and your experience, as well as allow us to see which areas and features of our Services are popular with our users and to count visits.

Information We Collect From Other Sources

We may also obtain information from other third party sources as far as it is necessary to perform our Services, and combine that with information we collect through our Services either directly as provided from you or automatically via your use and/or access. For instance, we may collect game ranking and achievement status from your console or mobile operating system game center application. Additionally, when you complete in-app purchases related to the Services, we may collect information about you from the provider of your device operating system when they process the in-app purchases on our behalf. Please note that we do not receive your payment method information from these operating system providers. In these cases, to the extent your consent is required under applicable laws, we will obtain your consent to collect, store, and use your information from such third parties in the format admitted by such applicable laws, and use such information we collected within the scope of purpose of use described in II. below.

II. Use of Information

We only collect, store and use your information if you have consented to it or, to the extent that it is necessary (i) for the performance of your agreement with us; (ii) to comply with our legal obligations; or (iii) for the purpose of our legitimate interests, including operating, evaluating and improving our global business. We have carefully balanced our legitimate business interests against your data protection rights. Please contact us using the contact details provided below if you have questions on this balancing of interests.

We (or a third party data processor acting upon our instruction) may collect, store and use information about you for the following purposes, for the periods necessary to achieve such purposes:

• Provide, maintain and improve our Services;
• Provide and deliver the products and services you request, process transactions and send you related information;
• Register you for an account on our Services and assist in the management of your account
• Respond to your comments, questions and requests and provide customer service;
• Send you technical notices, updates, security alerts and support and administrative messages;
• Communicate with you about products, services, offers, promotions, rewards, and events offered by ZIGZA and our other business partners, and provide news, information and other marketing materials that we think will be of interest to you;
• Monitor and analyze your trends, usage history and activities history in connection with our Services we obtained, and use such information for advertising of products/services according to your personal preference;
• Process and deliver contest entries and rewards promoted by ZIGZA;
• Personalize and improve the Services by analyzing your use history of our Services and/or purchase history,etc. according to your needs, and provide in-Service advertisements, content or features that match user profiles or interests;
• Link or combine the information we obtained (such as your use history of our Services and/or purchase history, etc.) with information we collect from other third parties, and analyze such combined information to help understand your needs and provide you with better service;
• Detect, investigate and/or prevent fraudulent, unauthorized or illegal activity;
• For any other purpose required or authorized for us to comply with our legal and regulatory obligations; and
• For any other specific and clear purpose which you and we separately agreed, when you provided the information.

[Purpose of Use of Specific Personal Information]

• For preparing a Payment Record required by the relevant laws and regulations, and for any other service related to this matter.

III. Sharing of Information

We do not share, sell, transfer or otherwise exchange your personal information with third parties, unless permitted by law, or unless you have given us prior consent to do so. In compliance with the aforementioned, we may share information about you as follows or as otherwise described in this Privacy Policy:

• With other users if you choose to participate in the interactive areas of our Services, such as community forums (however, the use of personally identifiable data (such as your full name) as a username in our services is strictly prohibited under our Service terms of use);
• With our employees, affiliates, related companies, vendors, consultants and third party service providers who need access to such information to carry out work on our behalf (including, for example, payment processors, website hosting services, or information storage and processing service providers);
• In response to legal process or a request for information if disclosure is in accordance with, or as otherwise required by, any applicable law, rule, or regulation (including, for example government or regulatory bodies, law enforcement agencies, or competent courts of law);
• With law enforcement agencies, government authorities, third party service providers and professional advisors (such as legal counsel) if we have reasonable grounds to believe your actions are inconsistent with our user agreements or policies, or to protect the rights, property and safety of ZIGZA, our users or others, and if it is difficult to obtain your consent;
• In connection with any merger, sale of company assets, or acquisition of all or a portion of our business to another company; and
• With your consent or at your direction.

[For Specific Personal Information]

Notwithstanding foregoing, we do not share the Specific Personal Information to any third party except for the cases specified by Article 19 of Act on the Use of Numbers to Identify a Specific Individual in Administrative Procedures of Japan.

IV. Advertising and Analytics Services Provided by Others

We may allow other third parties to provide analytics services on our behalf and to serve advertisements within our Services. These entities may use technologies to automatically collect information about your device and your use of our Services, including IP address, Cookies, information specific to the device such as device ID, time spent on pages within our Services, and links clicked within our Services(hereinafter, the programs using such technologies are referred to as “Information Collection Modules”). Such information does not include any personally identifiable information. Further, this information may be used by us and others to, among other things, maintain, improve, and analyze the functioning of our Services and deliver contextual or targeted advertising that may be of interest to you. The use of your information by these third parties is covered by their respective privacy policies, and we do not control and are not responsible for the privacy practices of such third parties.

Some of our Services will, with your prior consent, combine game play and analytic information with information collected from other ZigZaGame Inc. games, games from our group companies, and other third party sources to analyze game and monetization trends, create profiles of categories of players, create new games and services, and perform other analytics. We also use certain information collected through our games for advertisement targeting outside of the game. This includes creating profiles of types of players by combining your data with information from our advertising partners, providing the data to our ad agencies and ad platforms to target advertisements of our (and our group company) games and services to you outside of this game, and otherwise performing advertising analytics and performance metrics.

The name of the Information Collection Module used in this Service, their suppliers and the purpose of use of acquired information are as follows. Your information obtained by the Information Collection Modules is transmitted to the provider of each Information Collection Module, and used and managed in accordance with the privacy policy and/or any other related policies of such provider (hereinafter, collectively referred to as the “Provider’s Relevant Policy”).

V. Social Sharing Feature

The Services may offer social sharing features or other tools, which let you share actions or link the Services with social media. The use of such features enables the sharing of information with your friends or the public, depending on the settings you establish with the social media platform. For more information about the purpose and scope of data collection and processing in connection with social sharing features, please visit the privacy policies of the social media platforms. Please note that we do not control and are not responsible for the privacy practices of such social media platforms.

VI. Security

We take the following reasonable technical and organizational measures to help protect information about you from loss, theft, misuse and unauthorized access, disclosure, alteration and destruction:

• We have established a basic policy stipulating a compliance with relevant laws, regulations and guidelines, as well as the point of contact for questions and complaints on handling of personal information;
• We have established basic handling rules for acquiring, using, and storing, etc. of personal information;
• We have appointed a person in charge of the handling of personal information, and have established a system for reporting and communicating from employees to such person in charge;
• Clauses concerning the confidentiality of personal information are stipulated in our employment regulation;
• We take measures to ensure that any person, other than the data subject and the employee who is authorized to handle the personal information, is not able to easily access the personal information;
• We have introduced a mechanism for protecting any equipment used for handling personal data from unauthorized access and/or from unauthorized software; and
• We have implemented security control measures with the understanding of the system for personal data protection in the United States, where the personal information is stored.

However, no transmission over the internet can ever be guaranteed secure so we cannot guarantee the security of any personal information that you transfer over the internet to us.

VII. Storing and deleting data

Personal information collected through the Services is being stored and deleted in compliance with this Privacy Policy as well as privacy requirements under applicable law. All data will be de-identified or deleted if no longer required for the purposes mentioned above, unless further retention is required by law. Please contact us using the contact details provided below, if you have any questions with respect to our data retention practices.

VIII. International Transfers

We are based in Japan, and personal information that we collect from you is usually transferred, stored and processed in Japan. Therefore, please be aware that we may transfer your personal information to locations outside of your country, including Japan, which may not offer the same level of data protection as your country’s laws. However, our collection, storage and use of your personal information will continue to be governed by this Privacy Policy, and where we do disclose your personal information to third parties located outside of Japan (including countries/areas which may not offer the same level of data protection as laws of Japan or European Economic Area), we take such steps as are reasonably necessary in the circumstances to ensure it is appropriately used in accordance with this Privacy Policy and any applicable laws and regulations.

IX. Third Party Sites

Our Services contains links to other websites or services operated by third parties. Please note that this Privacy Policy applies only to our Services and we cannot be responsible for personal information that third parties may collect, store and use through their website. You should always read the privacy policy of each website you visit carefully.

X. Push Notifications/Alerts

ZIGZA may send push notifications or alerts to your device. You can deactivate these messages at any time by changing the notification settings on your device. ZIGZA will send push notifications or alerts with promotional content only after your prior opt-in to receiving such messages on your device.

XI. Data Protection Rights

You, and your legal guardian if you are a minor, may be able to exercise certain data protection rights under applicable law. Your rights under applicable law may include:

• Access to the personal information we process about you as well as the right to data portability,
• The right to have personal information corrected or erased,
• The right to restrict the processing of your personal information,
• The right to withdraw your consent at any time for consent we have obtained from you, although this will not affect the lawfulness of the processing prior to the withdrawal.
• You have also have the right to object, at any time, to the processing of your personal information which is based on ZIGZA’s legitimate interests.
• Where we process your personal information for direct marketing purposes, you have the right to object at any time to such processing, including for profiling purposes to the extent that it is related to direct marketing. If you object to processing for direct marketing purposes, we will no longer process your personal information for such purposes. In that case we may still send you transactional or relationship messages, but only about our ongoing business relations.

To exercise these rights, you should make a request using our contact details set out below. If you are not satisfied with the way we handle your request, you may lodge a complaint with a supervisory authority in your country of residence.

If you refuse to provide your personal information or request we delete or cease collecting your personal information, you may not be able to use all or some parts of our Services.

XII. Contact

If you have any questions or complaints about this Privacy Policy or our practices, please contact us at: