Effective Date: March 29th, 2024

INTRO

With this Privacy Policy, we aim to explain how and why we gather, store, share and use your personal data in a manner consistent with the laws of the countries where we do business. If you use our services, you agree to this privacy policy.

Where this Policy refers to "personal data" we mean any data or information that identifies, relates to, describes, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular natural person or household or any other data or information that constitutes "personal data," or "personally identifiable information".

HOW WE COLLECT YOUR PERSONAL DATA

We may collect personal data directly from you or third-party companies who have obtained your consent or have another legal right to share such personal data with us (including advertising platforms, partners and data aggregators who have obtained it). This may include attributes about you and your interests, as well as other games and services you use, demographic and general location information. We will use your personal data as described in this Privacy Policy.

Personal Data Collected Directly from You

We processes your personal data in order to provide the Services when you download, access and/or play our games or using our other Services. Most of this data comes directly from you. We collect the following information you provide in connection with our Services:

• Contact Information, including your country or region, or username.
• User Generated Content, including any files, documents, videos, images, data, or information you choose to upload or transmit through your communications with us or your use of the Services.
• Profile and Gameplay Information, such as your screen name, avatar or profile picture; your in-game scores, achievements and purchases; the competitions you enter and your membership and participation in teams on the Services.
• Survey Information, including feedback and ratings you provide relating to our Services.
• Inferences, such as information generated from your use of the Services, reflecting predictions about your interests and preferences.
• Parental Information, parent’s e-mail address and PIN to be created, only if you activate parental control setting in the Services.

We use this data to provide our games and Services to you, including optimizing our Services, customization of in-game offers and verifying purchases. We may also use it for the other purposes set out in this Privacy Policy.

Personal Data Collected from Third Parties

As mentioned above, most of the information that we collect about you comes directly from you when you play our games or interact with our Services. However, when you allow third-party companies access to your personal data (e.g., downloading our mobile applications through App Store or Google Store and linking your Facebook account to mobile applications), we also collect information from such third parties.

PURPOSES FOR PROCESSING OF YOUR PERSONAL DATA

We collect and use your personal data for the following purposes:

Business Purposes: Provide the Services and support; fulfill orders and requests; improve the Services and our business; develop new products and services; enhance your experience on the Services; protect the security for our users, employees, facilities, and Services; and develop internal marketing and demographic studies

Commercial Purposes: Market and advertise our and our business partners' products and services; send you promotional materials; and administer promotional activities or events.

We also use your information as permitted by law.

DISCLOSURE OF YOUR PERSONAL DATA

We may also share, transmit, disclose, grant access to, make available, and provide personal data with and to the third parties. We disclose your personal data for the purposes set forth in this Privacy Policy to provide the Services to our third-party service providers, to comply with legal obligations, and to protect and defend our rights and property.

THIRD-PARTY DATA COLLECTION AND ONLINE ADVERTISING

We participate in interest-based advertising and use third-party advertising companies to serve targeted advertisements based on your browsing history.

COOKIES

Like most online services, our website uses the following types of cookies:

• Strictly Necessary cookies. These cookies are essential for the proper functioning of our website.
• Functional cookies. These cookies enable a website to remember information that changes the way the website behaves or looks, like your preferred language or the region that you are in. The legal basis for our use of functionality cookies is our legitimate interests, namely being able to maintain our website.
• Analytical/performance cookies. These cookies allow us to recognize and count the number of visitors to our website, to improve how our website works and to see how visitors move around our website.
• Advertising/targeting cookies. These cookies only work during your visit to our website due to the presence of videos linked to third-party streaming platforms. They are typically used to track the visitors’ online activity on our website, and display more relevant advertisements.

· A. GameAnalytics　The Services use GameAnalytics, a SDK for collecting and analyzing game data provided by GameAnalytics Ltd. which may also collect information under their own privacy policies. GameAnalytics makes it possible to collect and analyze the data of the Services. GameAnalytics collects personal information as described below and aggregated information (information about groups or categories of persons, which does not identify and cannot reasonably be used to identify an individual person). The information held in log files includes the user's carrier name, device name, device OS name, device OS version, advertising identifier (IDFA / AAID), startup information, and billing information. You may refuse the use of GameAnalytics by opting out of measurement on the Service's settings menu.

· B. Advertisement tracking tool and ADNW　The Services use advertisement tracking tools and ADNWs (“Tools”) for smartphone applications provided by the following companies, to distribute advertisements on the Services. These companies may also collect information under their own privacy policies. Tools make it possible to measure and analyze the effectiveness of smartphone advertising and deliver advertising effectively. Tools collects personal information as described below and aggregated information (information about groups or categories of persons, which does not identify and cannot reasonably be used to identify an individual person). The information held in log files includes the user's IP address, carrier name, device name, device OS name, device OS version, advertising identifier (IDFA / AAID), startup information, and billing information. You may refuse the use of Tools by opting out of measurement on the Service's settings menu.

1. Firebase

2. Applovin MAX

3. Unity Analytics

YOUR RIGHTS

Being a user of our Services, you may have certain rights in connection with your personal data and how we handle it. You may be able to exercise these rights by contacting us at (email: support@rightcode.co.jp)

You may also be a user in the EU and may have rights under the EU General Data Protection Data Privacy Regulation, or a user in Virginia and may have rights under Virginia Consumer Data Protection Act, or a user in Brazil and may have rights under Lei Geral de Proteção de Dados Pessoais, or a user in any other country having local regulations.

Those rights include:

• Access to personal data: You have the right to access your personal data that We uses.
• Correction or deletion of personal data: You have the right to ask We to correct or complete your personal data if it is wrong or incomplete. You may also have the right to ask We to delete your personal data when certain conditions apply.
• Account deactivation: Should you wish to deactivate your account completely, you can disassociate your Facebook account from our mobile games and delete our games from your mobile devices. Please note that if you completely deactivate your account, all your progress in our games and any unspent virtual items will be lost, and we may not be able to restore them in the future.
• Restriction on processing personal data: You may have the right to ask We to restrict the use of your personal data when certain conditions apply.
• Object to processing of personal data: You may have the right to object to the use of your personal data by We when certain conditions apply.
• Portability of personal data: You may have the right to receive your personal data in a structured and commonly used format so you can use this data with another company when certain conditions apply.
• Right to opt out of:
• Targeted advertising: You may have the right to direct us not to process your personal data to provide targeted advertising.
• Certain types of profiling: You may have the right to direct us not to process your personal data for certain types of profiling activities.
  To use the right to opt-out, you can contact us by any method described in the Contact Us section below. Please also see the Control Over Your Information section of this Privacy Policy for detailed information.
• Right to non-discrimination. You may have the right not to receive discriminatory treatment for exercising these rights. However, please note that if the exercise of these rights limits our ability to process personal data (such as in the case of a deletion request), we may no longer be able to provide you with our products and services or engage with you in the same manner.
• Right to appeal. If we decline to take action on a request exercising one of your rights set forth above, you may have the right to appeal our decision.
• Right to Withdraw Consent. There are certain circumstances where we require your consent to process your personal data. In these instances, and if you have provided consent, you may have the right to withdraw your consent. If you withdraw your consent, this will not affect the lawfulness of our use of your personal data before your withdrawal.

We may need to verify your identity and confirm that you are a California resident in certain circumstances.

In certain circumstances, we may decline a request to exercise the rights described above, particularly where we cannot verify your identity or locate your information in our systems. If we cannot comply with all or a portion of your request, we will explain the reasons for declining to comply with the request.

European, UK and Swiss Residents: You also have the right to lodge a complaint to your local data protection authority. If you are based in the European Union, information about how to contact your local data protection authority is available here. If you are based in the UK or Switzerland, your local data protection authorities are the UK Information Commissioner's Office (https://ico.org.uk/global/contact-us/) and the Swiss Federal Data Protection and Information Commissioner (https://www.edoeb.admin.ch/edoeb/en/home/the-fdpic/contact/address.html).

California Residents: You have the right to know whether your personal data is sold or shared and the right to opt-out of the sale or sharing of your personal information by us for targeted advertising purposes.

Authorized Agents: In certain circumstances, you are permitted to use an authorized agent (as that term is defined by the CCPA) to submit requests on your behalf through the designated methods set forth in this CA Notice, where we can verify the authorized agent's authority to act on your behalf.

Virginia Resident: You have the right to know whether your personal data is sold or shared and the right to opt-out of the sale or sharing of your personal information by us for targeted advertising purposes.
To opt out of (i) targeted advertising, (ii) the sale of your personal data, and/or (iii) profiling, you can contact us by any method described in the Contact Us section below. Please see the Control Over Your Information of this Privacy Policy for detailed information.

CHILDREN

We do not intend to or knowingly collect personal data from children. We use the term "children" to refer to someone who is (a) under 13 years old or, if older (b) between 13 and 17 years old but under the age at which they can give valid consent to the processing of their personal data under applicable local or regional laws.

THIRD PARTY WEBSITES

Our Services may include links to third-party websites, plug-ins and applications. Except where we post, link to or expressly adopt or refer to this Privacy Policy, this Privacy Policy does not apply to, and we are not responsible for, any personal data practices of third-party websites and online services or the practices of other third parties.

CHANGES TO THIS PRIVACY POLICY

We may update this Privacy Policy from time to time, and we will post the updated Privacy Policy on this page. Any new policy will be effective from the date it is published by us.

CONTACT US

Right Code Inc.

address：1-1-29 Daimyo, Chuo Ward, Fukuoka City, Fukuoka Prefecture 810-0041 JAPAN

https://rightcode.co.jp/

Email：support@rightcode.co.jp