Colopl
App Privacy Policy

I. SUMMARY PRIVACY POLICY

COLOPL, Inc. (Midtown East 6F Akasaka 9-7-2, Minato-ku, Tokyo 107-0052, Japan)("Colopl" or "we" or "our") takes data privacy seriously. This App Privacy Policy ("Policy") informs users of the game app named “NEKO GOLF -Anime GOLF-” and any other Colopl-owned websites or mobile applications on which this Policy is displayed (together "App") how Colopl collects and processes data and information of any kind (e.g., your email-address etc.) about or related to you, even if such information cannot directly identify you on its own but can identify you in combination with other information that is stored by us ("Personal Data")in connection with the App and our games distributed via the App (collectively, the "Service").

1. Scope of Applicability

This Summary and the Full Privacy Policy (together the "Privacy Policy") apply to you if you use the App.

2. Processing of your Personal Data

We collect and use the following Personal Data related to your use of the App:

a. Information you provide to us, such as account data, data gathered for in-app purchases or communications and SNS ID, e.g., your nickname; pictures for your user icon; password; date of birth; type and amount of items purchased; purchase price; order date; an allocated password for your account; SNS ID; payment details; the platforms where the user makes payments; in-game activities and achievements; your name, email address and any other information provided by you in the communication.

b. Information that we collect automatically (as the case may be, subject to your consent), such as your player code, IP address, device name, name and version of OS, crash report information, technologies such as advertising ID, in-game activities and achievements. For more information, please read Section 1 .b of the following Full Privacy Policy.

c. Information we receive from third parties, e.g., payment details from the platforms. For more information, please read Section 1 .c of the following Full Privacy Policy.

3. Processing Purposes

We collect and use your Personal Data related to your use of the App to provide you with features and functions of the App, to address your inquiries, to conduct marketing activities, and to improve our services. Please read Section 2 of the following Full Privacy Policy to learn more.

4. Legal Justifications for the Processing of the Collected Data

One of the key privacy law requirements is that any processing of Personal Data has to have a legal justification. We generally use the following legal justifications: the Processing is necessary for (i) the performance of a contract, (ii) compliance with a legal obligation, (iii) realizing a legitimate interest, and, (iv) if you have provided your prior consent, we also rely on such. For more information, read Section 3 of the following Full Privacy Policy.

5. Data transfers and Recipients including International Data Transfers

In accordance with applicable law, we transfer your Personal Data to our service providers, and, as the case may be, governmental authorities, courts, external advisors, and similar third parties. Some of the aforementioned recipients are located outside of your country such as the United States, Japan, and/or other jurisdictions that may not provide the same level of data protection as your home country. For more information, read Section 4 of the following Full Privacy Policy.

6. Retention periods for and deletion of Collected Data

Collected Data will generally be deleted once it is no longer needed for the purposes of their original collection or as required by applicable law. For more information, please read Section 5 of the following Full Privacy Policy.

7. Your statutory rights

As provided by applicable law, you have certain rights with regard to the processing or handling of your Personal Data, such as the right to access your data, to have your Personal Data corrected, or erased. Please refer any questions to privacypolicy@colopl.co.jp. For more details read Section 6 of the following Full Privacy Policy.

8. Changes to this Privacy Policy

From time to time, we may have to update this Privacy Policy. We will let you know of any material changes to this Privacy Policy through your account. For more details read Section 9 of the following Full Privacy Policy.

9. Contact Information and how to contact Us

If you wish to exercise your data subject rights, have a privacy concern, complaint or any other question, please contact privacypolicy@colopl.co.jp.

The contact details of our representative within the EU are as follows:
Name: Enobyte GmbH
Address: Augustenstr. 49, D-80333 Munich
email:colopl.eurep@enobyte.com

II. FULL PRIVACY POLICY

1. Categories of Personal Data - What Personal Data do we process about you?

We process the following Personal Data related to your use of the App.

a. Personal Data you provided to us

Account data: If you create an account in our App, you may be asked to provide the following Personal Data: nickname, pictures for your user icon, an allocated password for your account your age, and date of birth.

Data gathered for in-app purchases: If you purchase any in-app items, we may collect and process the following types of data: date of birth; type and amount of items purchased; purchase price; order date; selected password for your account; payment details, including the platforms where the user makes payments; in-game activities and achievements.

SNS ID: If you choose to link your SNS account to the App, we may collect and process the following types of data: SNS account ID.

Communications: If you contact us with any queries, requests or complaints, for customer support or technical support, or to exercise your rights, we may collect and process the following types of data: your name, email address, in-game activities, message ID and achievements if necessary and any other information provided by you in the communication.

Payment account data: If you win any in-game event, you may be asked to provide the following types of data: your name, email address, payment services data and bank account data.

Contents: If you posted any text, characters, symbols, images, videos, audios, voice, and all other expressions which are created by you, including, but not limited to, any comments or posts by you (collectively "Contents") on the App in order to communicate with other users, we may collect and process such Contents.

b. Personal Data we collect by technical means

Metadata: When you use the App, we will collect the following metadata that results from your usage of the App:player code, device information including device name, name and version of OS, crash report of the App and internet protocol (IP) address.

In-game activities and achievements: When you play the game in the App, we will collect and process your in-game activities and achievements.

Advertising ID: Please see Section 7 for more information.

Ad serving and traffic measurement services
We may use the following third-party network advertisers to post advertisements. Ad network providers and advertisers may collect and process your Personal Data or other information about your use of the App over time. The information such ad network providers and advertisers may collect include your Advertising ID, device ID, IP address, in-game activities and purchase data and technical data about Software Development Kit. Those information may be used to, among other things, target advertisements, prevent you from seeing the same advertisements too many times or conduct research regarding the usefulness of certain advertisements to you. For further information, please see privacy policies of these third-party network advertisers:

a) Ironsource
URL：https://www.is.com/
Privacy Policy：https://developers.is.com/ironsource-mobile/ironsource-mobile-privacy-policy/

b) Pangle
URL：https://www.pangleglobal.com/jp
Privacy Policy：https://www.pangleglobal.com/jp/privacy/enduser-ja

c) Admob
URL：https://admob.google.com/intl/ja/home/
Privacy Policy：https://support.google.com/admob/answer/10502938?visit_id=637813711682453741-1493626176&rd=1

d) Unityads
URL：https://unityads.jp/
Privacy Policy：https://unity3d.com/jp/legal/privacy-policy

e) Tapjoy
URL：https://www.tapjoy.com/ja/
Privacy Policy：https://www.tapjoy.com/ja/legal/players/privacy-policy/

f) Applovin
URL：https://www.applovin.com/
Privacy Policy： https://www.applovin.com/privacy-jp/

g) Vungle
URL：https://vungle.com/
Privacy Policy：https://vungle.com/privacy/#section-2-3

h) facebook(Meta)
URL：https://www.facebook.com/audiencenetwork/
Privacy Policy：https://www.facebook.com/about/privacy/update

i) Adcolony
URL：https://www.adcolony.com/better-technology/
Privacy Policy：https://www.adcolony.com/privacy-policy/

j) Adjust
URL：https://www.adjust.com/
Privacy Policy：https://www.adjust.com/ja/terms/privacy-policy/

c. Personal Data we receive from third parties

Payment details from the platforms: If you purchase any in-app items, the platforms may share us the payment detail information, such as the country, platforms where the user makes payments, order ID, purchase price, currency, type and amount of items purchased and device name.

2. Processing Purposes - Why do we process your Personal Data?

We will use the Personal Data collected from you for the following purposes:

Account creation and management: We use your Personal Data to create and manage your account that can be used to sign-in to the App and other related services, and record your game playing.

Service provision:
We use the Personal Data to operate, maintain, enhance and provide features and functions of the App and the Service, including the following activities:

• Operating the App and the Service including recording of game play. We will process your Personal Data to operate the App and the Service. For example, we will process your Personal Data to record your game play, to allow you to start playing the game where you left off, to make it easy for you to sign-in to the App and provide appropriate game software for your device. In addition, SNS ID and passwords will be used when you choose to sign in with such SNS account.
• Processing in-app purchase, calculating sales, managing amount pre-paid by you. We will process your Personal Data to process your in-app purchase, manage the amount you prepared in the App for future in-app purchases, to calculate the remaining amount you prepared in the App and to calculate our sales amount.
• Conducting in-game events. We will process your Personal Data to pay premiums to the users who win the event.
• Identifying and fixing bugs, verifying service reliability. We will process your Personal Data in order to identify and fix the bug of the App and the Service and to verify service reliability. Crash report information will be recorded and processed in order to identify and fix the bugs and restore your game play.
• Managing of access log. We will process your device's IP address to manage your access log.
• Transferring the data to a new device. When you play the game on another devices, we will process your SNS ID to transfer the data to the new device.

Communications: We use the Personal Data to communicate with you about the App and the Service for administrative and informational purposes. Examples of such communications include responses to your inquiries or requests, customer/technical support-related communications, and changes to any of our terms & conditions or policies.

Improvement and development of App and Service: We use the Personal Data to optimize and improve our Service, and to develop new services, contents, events, items, features and functions by analyzing and understanding the usage trends and preferences of our users in order to enhance your user experience.

Compliance with law: We use the Personal Data to ensure compliance with our internal policies, agreements with our stakeholders, applicable laws and regulations, court orders, government and law enforcement requests. We may also use the Personal Data to enforce or defend our legal rights or the terms and conditions of any our service, or to retain and store your personal information to comply with specific legal retention requirements, regulatory audits, and other record keeping purposes (including to meet internal and external audit requirements).

Protection of the security or integrity of the App, including fraud prevention and investigation: We may use the Personal Data to monitor, prevent, detect, investigate and report illegal and illicit activities, including fraud and misuse of the App. We will also use the Personal Data to maintain the integrity and security of the App and the Service and preventing and detecting security threats, fraud or other criminal or malicious activity that might compromise your devices.

Marketing activities: We will use your Personal Data to improve our marketing activities by analyzing your interests, the number of users who download the App, advertisements from which users accessed the App.

3. Processing Basis and Consequences - What is the legal justification for processing your Personal Data and what happens if you choose not to provide it?

We rely on the following legal grounds for the collection, processing, and use of your Personal Data:

• the processing is necessary to provide the App and its Services to you;
• your consent to the processing of your data for one or more specific purposes;
• the processing is necessary for the performance of a contract to which you are a party or to take steps at your request prior to entering into a contract;
• the processing is necessary for compliance with a legal obligation to which we are subject;
• the processing is necessary for the purposes of the legitimate interests pursued by us or by a third party, except where such interests are overridden by the interests or fundamental rights and freedoms of you which require protection of Personal Data, in particular if you are a child; such legitimate interests are the fulfilment of the processing purposes set out above in Section 2, in particular we have a legitimate interest in using the Personal Data　to improve and develop our App or Services and improve the safety, security, integrity and performance of the App and the Service. When we process the Personal Data for our legitimate interests, we make sure to consider and balance any potential impact on you, and your interests, rights and freedoms under any applicable laws. We will not use your Personal Data for any processing where our interests are overridden by the impact on you, unless we have your consent for our processing, or are otherwise required by law. You have the right to object to processing that is based on our legitimate interests, as indicated in Section 6 below;

The table below summarizes the Personal Data processed for the respective purposes as well as the applicable legal basis.

The provision of your Personal Data is necessary to enter into a contract with us or to receive our services as requested by you.

Not providing your Personal Data may result in disadvantages for you--for example, you may not be able to receive certain services. However, unless otherwise specified, not providing your Personal Data will not result in legal consequences for you.

4. Categories of Recipients and International Transfers - Who do we transfer your Personal Data to and where are they located?

We will not share any of your Personal Data that we have collected except as described below:

Service providers: We may use service providers to process Personal Data for the purposes described in Section 2, including lawyers, accountants, auditors, etc., in accordance with applicable laws.

Government authorities: We may transfer Personal Data to law enforcement agencies, governmental authorities, judicial authorities and courts in order to comply with any applicable laws, respond to any legal claims against us, protect or defend ourselves or other third parties against any illegal, criminal or harmful activities.

Business transactions: In the event of a corporate merger or acquisition, Personal Data may be transferred to the third parties involved in the merger or acquisition.

Advertising networks and their partners:
In order to provide personalized advertisements to you, third-party advertising networks and their partners will directly collect and process your personal data including device ID, IP address, technical data about Software Development Kit, your behavior on the App, ads posted, ads viewed or clicked by you, advertisement ID, device's operating system, etc. Such processing is governed by the privacy policies and cookie policies of such third parties (please see Section 1 for more details).

Any access to your Personal Data is restricted to those individuals that have a need-to-know in order to fulfill their job responsibilities.

International transfers. You should expect that the recipients identified above which will receive or have access to your Personal Data, are located inside or outside your country.

• For recipients located outside of your country, some are located in a country that the data privacy authority in your country has deemed to provide an adequate level of protection for Personal Data under the applicable data protection law.
• Other recipients might be located in countries that do not adduce an adequate level of protection from the applicable data protection law perspective. We will take all necessary measures to ensure that transfers out of your country, are adequately protected as required by applicable data protection law and to ensure that appropriate technical and organizational security measures are in place to protect Personal Data against accidental or unlawful destruction, accidental loss or alteration, unauthorized disclosure or access, and against all other unlawful forms of processing.
  • With respect to transfers to countries not providing an adequate level of data protection, we will base the transfer on appropriate safeguards, such as appropriate data transfer agreement including standard data protection clauses adopted by a supervisory authority, approved codes of conduct together with binding and enforceable commitments of the recipient, or approved certification mechanisms together with binding and enforceable commitments of the recipient. You can ask for a copy of such appropriate safeguards by contacting us as set out in Section 8 below.
  • The data transfer to processors which are not in a country providing an adequate level of data protection will typically also be protected by such appropriate data transfer agreement.
• Any onward transfer is subject to appropriate onward transfer requirements as required by applicable law. Nonetheless, this may impact your data subjects rights in your local jurisdiction and also in the applicable overseas jurisdiction(s). These overseas jurisdictions may also need to disclose your Personal Data to a third party, e.g., an overseas authority. If you have any questions or concerns about our data transfer arrangements, please contact us as stated under Section 8 below.

5. Retention Periods - How long do we keep your Personal Data?

Your Personal Data will be retained as long as necessary to provide you with the services requested. If you have consented to the processing of your Personal Data, we will store such Personal Data at least until you revoke your consent. If we need your Personal Data to carry out a contract between you and us, we will store such data for as long as the contractual relationship or statutory retention periods allow us. If we use your Personal Data based on our legitimate interests, we will store such data for as long as our purposes continue and so long as your fundamental rights do not override our legitimate interests. Please note that we may be required to retain certain information by law. In principle, we will retain the Personal Data only as long as required or permitted by applicable law, in particular as long as the Personal Data may be needed to fulfill or defend against claims that are not yet time-barred.

6. Your Rights - What rights do you have and how can you assert your rights?

Right to withdraw your consent: If you have declared your consent regarding certain collecting, processing and use of your Personal Data, you can withdraw this consent at any time with future effect. Such a withdrawal will not affect the lawfulness of the processing prior to the consent withdrawal. You can withdraw your consent as follows by contacting us as stated under Section 8 below.

Additional data privacy rights: Pursuant to applicable data protection law, you may have the right to: (i) request access to your Personal Data (ii) request rectification of your Personal Data; (iii) request erasure of your Personal Data; (iv) request restriction of processing of your Personal Data; (v) request data portability; and/or (vi) object to the processing of your Personal Data (including objection to profiling). Below please find further information on your rights to the extent that the General Data Protection Regulation (“GDPR”) applies. Please note that these rights might be limited under the applicable local data protection law.

• Right to request access to your Personal Data: As provided by applicable data protection law, you have the right to obtain from us confirmation as to whether or not Personal Data concerning you is being processed, and, where that is the case, to request access to the Personal Data. This access information includes – inter alia – the purposes of the processing, the categories of Personal Data concerned, and the recipients or categories of recipient to whom the Personal Data have been or will be disclosed. However, this is not an absolute right and the interests of other individuals may restrict your right of access. You may have the right to obtain a copy of the Personal Data undergoing processing free of charge. For further copies requested by you, we may charge a reasonable fee based on administrative costs.
• Right to request rectification: As provided by applicable data protection law, you have the right to obtain from us the rectification of inaccurate Personal Data concerning you. Depending on the purposes of the processing, you may have the right to have incomplete Personal Data completed, including by means of providing a supplementary statement.
• Right to request erasure (right to be forgotten): As provided by applicable data protection law, you have the right to obtain from us the erasure of Personal Data concerning you and we may be obliged to erase such Personal Data.
• Right to request restriction of processing: As provided by applicable data protection law, you have the right to obtain from us that we restrict the processing of your Personal Data. In such case, the respective data will be marked and may only be processed by us for certain purposes.
• Right to request data portability: As provided by applicable data protection law, you have the right to receive the Personal Data concerning you, which you have provided to us, in a structured, commonly used and machine-readable format and you may have the right to transmit those data to another entity without hindrance from us.
• Right to object:
  

  Under certain circumstances, you have the right to object, on grounds relating to your particular situation, at any time to the processing of your Personal Data by us and we are required to no longer process your Personal Data. Such right to object especially applies if we collect and process your Personal Data for profiling purposes in order to better understand your interests in our products and services or for certain types of direct marketing.
  
  If you have a right to object and if you exercise this right, your Personal Data will no longer be processed for such purposes by us. You may exercise this right by contacting us as stated in Section 8 below.
  
  Such a right to object may, in particular, not exist if the processing of your Personal Data is necessary to take steps prior to entering into a contract or to perform a contract already concluded.

Please note that the aforementioned rights might be limited under the applicable national data protection law. To exercise your rights, please contact us as stated under Section 7 below. You also have the right to lodge a complaint with the competent data protection supervisory authority in the relevant member state (e.g., the place where you reside, work, or of an alleged infringement of the GDPR).

7. Advertising ID

General Information
This App uses Advertising ID, such as IDFA (Apple Advertising ID for iOS devices) and AAID (Google Advertising ID for Android devices).

When you launch the App, we or third parties may collect an Advertising ID from your device. The advertising ID is a unique, random, user-resettable alphanumeric string of digits for advertising assigned by the operating system of the device (e.g. Google, Apple ). Advertising ID is common and used on a number of apps.

Advertising ID allows us to collect information on the use of and the scope of use of the Service by individual users. This includes how many times a user has used the App, the movements of the users within the App, the overall App usage and areas that users prefer and so allows us to analyze the efficiency of our marketing activities and to provide targeted advertisement tailored for your interests. If you disable such Advertising ID, you will not receive a customized advertisement experience. The legal basis for the collection and further processing of such information by targeted advertisement is your consent.

Withdrawing consent

You can change this setting at any time. If you would like to change your settings, please contact us at the contact details provided in our Privacy Policy. Such a withdrawal will not affect the lawfulness of the processing prior to the withdrawal of consent.

However, please note that if you withdraw your consent or disable Advertising ID, you will not receive a customized advertisement experience.

8. Questions and Contact Information

If you have any questions about this Policy or if you want to exercise your rights as stated above in Section 5, please contact us at: privacypolicy@colopl.co.jp.

The contact details of our representative within the EU are as follows:
Enobyte GmbH
Augustenstr. 49
D-80333 Munich
Web: https://enobyte.com
e-mail: colopl.eurep@enobyte.com
Phone Number: +49 89 215 4774 -30.

9. Changes to this Policy

We may update this Policy from time to time in response to changing legal, regulatory or operational requirements. We will notify you of any such changes, including when they will take effect, by updating the "Last revised" date above or as otherwise required by applicable law. Your continued use of our App after any such updates take effect will constitute acceptance of those changes. If you do not accept updates to this Policy, you should stop using our App and Services.