Privacy Policy

GREZZO Co., Ltd. (hereinafter referred to as "Company") handles the user information acquired through the game applications (hereinafter referred to as "the Applications") operated by the Company regarding game applications provided through the "Apple Arcade" subscription service provided by Apple Inc. and its affiliates (hereinafter referred to as "Apple"), as follows.

Article 1 (General Provisions)
1. The Company will comply with the Act on the Protection of Personal Information (Act No. 57 of 2003; hereinafter referred to as "Personal Information Protection Act") and other related laws and regulations, etc. and strive to appropriately handle and protect users' personal information ("Personal Information" as defined in Article 2, Paragraph 1 of the Personal Information Protection Act; the same shall apply hereinafter).
2. This Privacy Policy (hereinafter referred to as "Policy") applies to the use of the Applications. If the Company posts a privacy policy on a separate website, etc. operated by the Company, such provisions shall also apply. However, if such provisions conflict with this Policy, this Policy shall prevail.

Article 2 (Information to be Acquired by the Company and the Method of Acquisition)
1. The Company may acquire and use user information, including Personal Information, on the Applications as set forth below.
(1) Gameplay data
(i) The user’s gameplay data (including but not limited to play progress, levels, and achievements) may be collected through the Applications. This gameplay data will not be used by the Company to personally identify the user and will not be linked in any way to information that personally identifies the user. This gameplay data will be stored locally on the user’s device and may also be saved to the Apple servers in accordance with terms governing the user relationship with Apple. In particular, the user’s achievement data is transmitted to the Game Center server. Provided, however, that the Company does not store this gameplay data on the Company servers.
(ii) In the case that the user want to disconnect gameplay data from Apple, the user can stop sending gameplay data to Apple through Apple's features. For more information about data by Apple, please refer to Apple's Privacy Policy.
(2) Information for The Mirage Cup
Notwithstanding the preceding item (3), the Company will store the user's gameplay data for the Mirage Cup (gameplay data of dragons and riders in game training) to the server (sakura internet) designated by the Company. The Company will connect such information to the user's Game Center ID and will use such information to conduct data matchup with other users.
- Gameplay data for dragons and riders includes status, skill information, and dragon growth parameters.
- Dragon names which personally identify the user will not be sent.
- The Company will ask the user's consent through a pop-up if the Applications transmit gameplay data.
2. When acquiring user information, including Personal Information, the Company will properly acquire such information without using deception or other wrongful means. If Personal Information is acquired by any method other than through the use of the Applications by the user, the Company will notify or publicly announce the purpose of use in advance.

Article 3 (Purpose of Use)
1. The Company will properly handle Personal Information acquired through the Applications within the scope of the following purposes. The information will not be used beyond the scope of the purpose of use without the consent of the user, nor will it be used in a manner that may encourage or induce illegal or unjust acts:
(1) Provision, maintenance and quality improvement of services provided by the Company　(including but not limited to detecting and fixing bugs and operability issues, detecting and prevent fraudulent or illegal activity and complying with legal obligations ), including the Applications ;
(2) Provide service communication and responding to customer service requests, etc. on the Applications.
2. The Company may change the purposes of use described in the preceding paragraph to the extent reasonably deemed relevant to the purposes of use prior to such change, and in the event of such change, the Company will notify the user or publicly announce such change by posting a notice on the Applications or otherwise.

Article 4 (Provision to Third Party)
1. The Company will not provide any Personal Information to third parties without the consent of the user, except as required by the Personal Information Protection Act or other laws and regulations, and as otherwise provided in this Policy.
2. The Company may provide users' Personal Information to third parties in the following foreign countries. In such cases, the information that should be referred to is as follows at this time.
United States of America
Please refer to the following link for information provided by the Personal Information Protection Commission on the Personal Information protection systems of such foreign countries.
https://www.ppc.go.jp/enforcement/infoprovision/laws/offshore_report_america/#federal
3. Personal Information may be provided to third parties in foreign countries other than those specified in the preceding paragraph, although the recipient business operator and the country in which the recipient business operator is located have not been identified, to select an appropriate business operator from time to time for outsourcing and joint use. In such cases, the information that should be referred to is as follows at this time.
https://www.ppc.go.jp/enforcement/infoprovision/laws/

Article 5 (Outsourcing of Handling of Personal Information)
The Company may outsource the handling of all or part of the Personal Information acquired from users to a third party within the scope necessary to achieve the purpose of use. In such cases, the Company will exercise necessary and appropriate supervision to ensure that the information is appropriately and safely managed by the third party to which it is outsourced.

Article 6 (Joint Use)
The Company will jointly use Personal Information as follows.
(i) Items of Personal Information to be jointly used
Items described in Article 2
(ii) Purpose of use of personal information to be jointly used
Purpose of use described in Article 3
(iii) Scope of joint users
Apple
(iv) Party responsible for management of joint use
The Company (3rd floor, Yushin Building Shinkan, 3-27-11 Shibuya, Shibuya-ku, Tokyo ; Representative Director: Koichi Ishii)

Article 7 (Safety Management System)
1. The Company will take necessary and appropriate measures to protect Personal Information, including preventing leakage, loss or damage.
2. The Company will assign a person responsible for the management of Personal Information, and will implement appropriate management and continuous improvement of Personal Information.
3. For more information on the security control measures taken by the Company, please contact "Inquiries" under Article 10.

Article 8 (User's Right to Disclosure and Correction, etc. of Personal Information)
For measures such as disclosure, correction, deletion or suspension of the use of Personal Information on the Applications or disclosure, etc. of records of provision to a third party, please contact the inquiry desk specified in Article 10 However, the Company may not be able to perform these procedures if the Company is not obligated to do so under the Personal Information Protection Act or other laws and regulations, if the same request is repeated many times without justifiable reason or if excessive technical work is required.

Article 9 (Changes to this Policy)
1. The Company will review the operation status regarding the handling of Personal Information from time to time, make efforts for continuous improvement and may change the Policy from time to time as necessary. If the Company makes a change to the contents of this Policy that requires the consent of the users under laws and regulations, the Company will obtain the consent of the users in advance by a separate method that it deems appropriate.
2. The changed Policy will be posted on the Applications or otherwise notified in an easy-to-understand manner and will become effective upon such notification.

Article 10 (Inquiries)
If you have any opinions, questions, complaints or other inquiries regarding the Company’s handling of Personal Information, please contact the inquiry desk below.
Address: 3rd floor, Yushin Building Shinkan, 3-27-11 Shibuya, Shibuya-ku, Tokyo 150 0002
Telephone number: 03-5469-5630
E-mail address: jd_support@grezzo.co.jp
Reception hours: 11:00-17:00

Business Operator Handling Personal Information
GREZZO Co., Ltd.
Address: 3rd floor, Yushin Building Shinkan, 3-27-11 Shibuya, Shibuya-ku, Tokyo 150 0002
Name of representative: Koichi Ishii

*Formulated on 6 1, 2023