Updated: [August 10, 2021]

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

Your privacy is important to DeNA. We designed our Privacy Policy to cover how we collect and use 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 it. If you have any questions, please contact us.

Contents

• The What
  Both non-personal information and personal information may be collected and used by us
• The Why
  The primary objective for collection and use is to deliver and improve our Services
• The When
  When you provide information to us, use the Services, or register or connect with a social gaming network or other social network service ("SNS") in connection with use of our Services
• The How
  By providing information to us directly, using the Services, or registering or connecting with an SNS in connection with use of our Services
  
  Cookies may be used, but options are available to remove/disable certain cookies by the settings on your browser
  
  Services-related promotions (including SMS) may also be used by us, but you will have the option to opt-out of these
  
  Geo location information may be collected from the Device, but unless you opted in, this will not be collected or used in a way that identifies you
• The Who
  We may share your information with persons who help us provide the Services, but only as necessary, and they must keep it confidential
  
  Except only in special circumstances, we never transfer your personal information to advertisers or marketers without your separate consent
  
  We do not knowingly collect personal information from children under 13
• The Where
  In line with this Privacy Policy, your information may be processed in Japan and other countries as necessary
• Changes to Privacy Policy
  We may change this Privacy Policy, so please check for any updates
• Other Important Matters
  Measures are taken to safeguard information received from you, and we keep your personal information only as long as necessary
• Information Notice for California Residents & Privacy Rights
  Certain provisions of this Privacy Policy are for California residents; if you are a California resident, you should confirm if they apply to you

The What

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, and might include your name, phone number, pictorial representation, email address, postal address, etc. 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).

The Why

Our primary objective in collecting your information is to provide you with a superior and personally relevant user experience. To achieve this, your information may be used as follows:

- To help us develop, deliver, and improve our Services, including the following aspects of our Services:

• messaging and other communication to and with users
• the creation, updating, accessing, and maintaining of lists of friends or contacts
• transactions for and use of virtual currency and virtual items
• social communication and user-interactive features
• the delivery and targeting of advertising in the Services
• tracking of advertisement fulfillment metrics in the Services
• recommending Services-related products or services of interest directly to you

- For market research purposes that support our efforts to deliver a more valuable service to our community of users, including using your 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.

- To provide end-user support.

- To prevent and take measures against fraud, illegal activities, infringement of our rights or interests, or breaches of our EULA and this Privacy Policy.

- To send important notices, such as changes to our EULA, this Privacy Policy, or other Services-specific policies. Because this information is important to your interactions with us, you may not opt out of receiving these communications.

- To audit and analyze data for technical administration, to improve our Services, and for end-user communications.

For location-based Services, we may collect, use, and share precise location data, including the real-time geographic location of the device you use to access or use our Services ("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.

The When

Your information is collected by us when you directly interact with our Services and otherwise through use of our Services via your Device.

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.

When you use our Services, we collect information related to your Device as described in "The How" section below. We may also collect information from you when you agree to receive SMS notifications from us concerning events in our games or other software, including the telephone number of your Device.

If you choose to participate in a Promotion, we may request that you provide us with personal information such as your name, email address or postal address in order to administer your participation in the Promotion.

The How

As already mentioned, we may collect information from you when you directly interact with our Services and otherwise through your access to or use of our Services.

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.

We may also collect your information from third parties who provide it to us, including other users of our Services.

As is standard practice, we do use "cookies" in connection with the Services. 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 log-in 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. Note that local shared objects or "flash cookies", which are different from HTTP cookies, may require different treatment for removal or disablement depending on the version of 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.

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.

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, information searched for, 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").

BY ACCESSING OUR SERVICES, YOU ARE CONSENTING TO THE USE OF COOKIES UNDER THE TERMS OF THIS PRIVACY POLICY.

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 with Whom We May Share Your Information

You agree that 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 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 in Japan and other countries. Your consent to this Privacy Policy by accessing or using our Services represents your consent to such transfer and processing.

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 (https://dena.com/legal/), 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

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 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.

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 or conspicuous posting on our website 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.

Corrections and Certain Opt-Out Options

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.

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.

For a Promotion, you have the option to opt out at any time from participation in such Promotion and the receipt of any related communications by following unsubscribe instructions provided in the relevant communications, or by selecting not to receive communications from us where the relevant media service offers that option.

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.

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.

Information Notice for California Residents & Privacy Rights

As described below, California residents may have additional rights and choices related to identifying information and other types of personal information.

This section covers how we collect and use your information in connection with the use of our official site for the Services and applies solely to California residents.

Summary of Information Practices

If you are a California resident, California law requires us to provide you with some additional information regarding how we collect, use, and share your “personal information” as defined in the California Consumer Privacy Act (“CCPA”).

Categories of personal information we collect and disclose.

Throughout our Privacy Policy, including in “The What” and “The When” sections, we discuss in detail the specific pieces of personal information we collect from and about users.

Under the CCPA, we are also required to provide you with the “categories” of personal information we collect. The categories we collect are:

• Contact information (for Promotion purposes), such as names, addresses, phone numbers, and email addresses;
• Online identifiers such as your IP address;
• Internet or other network or device activity such as browsing history or Services usage;
• General geolocation information (e.g., latitude-longitude coordinates based on IP address);
• Audio information, such as customer service call recordings if you do not opt out;
• Other information that identifies or can be reasonably associated with you; and
• Inference data from the information above.

We share all of above categories of personal information with:

• Our affiliates and subsidiaries;
• Our service providers, such as marketing and advertising services and providers of technical services (e.g., data storage, security, and customer relationship management databases); and
• Other parties where required by law or to protect our rights.

In some cases, the link between the data and the use or disclosure was more direct than others. The specific uses and disclosures in which service providers are involved varies from provider to provider.

How we use these categories of personal information.

We and our service providers may use the categories of personal information we collect from and about you for the following business purposes and commercial purposes (as those terms are defined in applicable law):

• Our or our service provider’s operational purposes;
• Auditing consumer interactions on our site (e.g., measuring ad impressions);
• Detecting, protecting against, and prosecuting security incidents and fraudulent or illegal activity;
• Bug detection and error reporting;
• Customizing content that we or our service providers display on the Services (e.g., contextual ads);
• Providing the Services (e.g., account servicing and maintenance, customer service, advertising and marketing, analytics, and communication about the Services);
• Improving our existing Services and developing new services (e.g., by conducting research to develop new products or features);
• Other uses that advance our commercial or economic interests;
• Other uses about which we notify you.

Examples of these types of uses are discussed in “The How” section of this Privacy Policy. We may also use the categories of personal information for compliance with applicable laws and regulations, and we may combine the information we collect (“aggregate”) or remove pieces of information (“de-identify”) to limit or prevent identification of any particular user or device.

Sale of Personal Information

We do not sell information that directly identifies you such as your name and email address. We share certain information as set forth in “The Who” section and allow third parties to collect certain information about your activity, for example through cookies, as explained in “The How” section. You can control these cookies through browser settings and other controls. We do not believe these activities are a “sale of personal information” as such terms are described under the CCPA.

Please note that we also do not knowingly sell the personal information of minors under 16 years of age without legally-required affirmative authorization.

California Privacy Rights

If you are a California resident, you may have certain rights. California law may permit you to request that we:

• Provide you the categories of personal information we have collected or disclosed about you in the last twelve months; the categories of sources of such information; the business or commercial purpose for collecting or selling your personal information; and the categories of third parties with whom we shared personal information.
• Provide access to and/or a copy of certain information we hold about you.
• Delete certain information we have about you.

You may have the right to receive information about the financial incentives that we offer to you (if any). You also have the right to not be discriminated against (as provided for in applicable law) for exercising certain of your rights. Certain information may be exempt from such requests under applicable law. For example, we need certain types of information so that we can provide the Services to you and for compliance with applicable law. If you ask us to delete certain information, you may no longer be able to access or use the Services.

If you would like to exercise any of these rights, please contact dena@opencs.dena.jp or by post Attn: DeNA Customer Support Center, Shibuya Scramble Square, 2-24-12 Shibuya, Shibuya-ku, Tokyo 150-6140 JAPAN. You can also designate an authorized agent to make a request on your behalf. To do so, you must provide us with written authorization or a power of attorney, signed by you, for the agent to act on your behalf. In all cases in which you (or your authorized agent) make a request to exercise your CCPA rights, you will be required to verify your identity directly with us, which may include, verifying certain information regarding your use of the Services or participation in a Promotion. If you are unable to verify your identity, we will be unable to respond to your request.

Contacting Us

If you have any questions, inquires, requests, or complaints concerning this Privacy Policy or our information collection practices, please contact us at dena@opencs.dena.jp or by post Attn: DeNA Customer Support Center, Shibuya Scramble Square, 2-24-12 Shibuya, Shibuya-ku, Tokyo 150-6140 JAPAN.