Basic Policy regarding the Protection of Personal Information
1. Basic Policy
i. Protection of personal information
The Company recognizes the importance of personal information, views the complete protection of personal information as its social responsibility, and promises to comply with the Act on the Protection of Personal Information, other relevant laws and regulations, guidelines, and the like, and to properly handle the personal information collected from the customers who use the Company’s services and the Company App in accordance with this Policy.
2. Handling of Personal Information
ii. Purpose of use
3. Administration System
i. Appointment of administrator and creation of internal rules
The Company has appointed a personal information protection administrator as the person responsible for the administration of the personal information. The Company has also created internal rules regarding the protection of personal information and is ensuring the proper handling of personal information.
ii. Information security measures
The Company restricts access to personal information for the purpose of preventing personal information from being leaked, destroyed, or damaged or for any other safety management purpose. The Company also provides training regarding the handling of personal information for its officers and employees who handle personal information.
iii. Destruction of information
When the Company reasonably determines that the collected personal information is unnecessary for the business operation of the Company’s services or upon the expiration of the individually specified retention period, the Company will dispose the personal information in its possession.
4. Provision to Third Parties
i. Disclosure to third parties
In the following cases, the Company may disclose personal information to third parties:
● The Company outsources work to a third party to the extent necessary to achieve the purpose of use
● The Company performs a merger, corporate spin-off, transfer of business, or disposes all or some of the Company’s business, assets, or stock (including cases where it is performed in connection with bankruptcy or similar proceedings)
● The Company requests the customer’s consent for the disclosure and the customer gives such consent
However, with regard to any information that has been statistically processed so that individual customers cannot be identified, the Company may use such information for purposes other than those listed above.
ii. Disclosure at the request of a government body, local government, public agency, or the like
In the following cases, the Company may disclose personal information to a public agency or the like:
● Pursuant to laws and regulations (including any laws and regulations outside of the country of residence of the party that will be providing the information)
● Disclosure is necessary to protect a person’s life, body, or property, and it is difficult to obtain the consent of the customer
● It is particularly necessary to improve public health or to promote the healthy development of children, and it is difficult to obtain the consent of the customer
● There is a need to cooperate with the performance of administrative work provided for by law or regulation by a national government body, local government, or a contractor for such body, and obtaining the customer’s consent may interfere with the performance of such administrative work
1. Collection of Personal Information; Purpose of Use i List of information that will be collected
The Company may collect the following information from you in connection with the provision of the App:
● UID of mobile device
● Name of mobile device
● MAC address
● Time zone
● Email address
● Installation source of the App
● Advertising-related information
● advertising ID
● UID of the App
● IP address
● Facebook ID
ii Purpose of use
The Company will use the collected information for the following purposes:
● Providing the services of the App
● Transferring the usage of the App
● Communication between users of the App
● Communication between you and the Company
● Achieving a secure and safe communication environment
● Measuring, studying, and analyzing the usage of the App and the results of implementing various measures
● Conducting marketing research and surveys
● Improving the App and fixing bugs
● Introducing various services, promotions, campaigns, events, etc. operated by the Company or a third party
● Displaying advertisements and optimizing the content of such advertisements
● Handling inquiries (including identity verification)
● Providing information to the third parties (including joint users) set forth in “3. Provision to Third Parties; Information Collection Modules”
iii Legal basis
The legal basis for the processing of your Personal Data is your consent.
2. Provision to Third Parties; Information Collection Modules and International Transfer of Information
i Provision to third parties
In the cases set forth in “4. Provision to Third Parties” of the “Basic Policy regarding the Protection of Personal Information,” the Company may disclose personal information to third parties.
ii Information collection modules
● New Relic “New Relic” https://newrelic.com/ (To study the crash reports for the App)
● adjust K.K. “adjust” https://www.adjust.com
(To identify and analyze the promotional effect for the App)
● Apsalar “Apsalar” https://apsalar.com/
(To identify and analyze the promotional effect for the App)
● Zendesk “Zendesk” https://www.zendesk.com/ (To provide customer support for the App)
● Facebook “Facebook” https://www.facebook.com (To identify and analyze the promotional effect for the App)
iii International Transfer of Information
Company may transfer information that Company collect about you to our affiliates or to other third parties that may be outside of your country. If you are located in the European Union origin, another country or jurisdiction, such locations may have laws governing data collection and use that differ from U.S. law. Please note that you are transferring such information and allowing Company or others to transfer such information, including personal information, to a country and jurisdiction that does not have the same data protection laws as your jurisdiction, and you consent to: (i) the transfer of such information to Goodbay Technologies, Inc., based in U.S and India, GREE, Inc., based in Japan, Funplex, Inc., based on Japan, and AltPlus, Inc., based in Japan; and
(ii) their use and disclosure of such information.
3. Method of Notices, Announcements, or Obtaining Consent; Method of User Involvement
i Notices and announcements
ii Method for obtaining consent
iii Suspension of collection and transmission of information
You may stop the collection and transmission of information by deleting (uninstalling) the App from your mobile device.
4. Request for Disclosure, Etc.; Inquiries
i Request for disclosure, correction, addition, deletion, suspension of use, etc.
If you or your agent: (i) makes a request (a) to access, disclose, correct, or delete your personal information, (b) to restrict or suspend the use of your personal data, or (c) data portability; or
(ii) exercise the right to object the use of your personal data , the Company will comply with such request without delay to the extent possible in accordance with laws and regulations. If you wish to make such request, please inform us by following the process described on our support page as follows. Please note your account may be deactivated if you delete certain of your personal information. You have the right to complain to the supervisory authority.
Support Page https://dragonsoul.zendesk.com/hc/en-us
If you wish to make an inquiry, to discuss, or to file a complaint with regard to the handling of personal information in connection with the App, please contact the Company after reviewing the Company’s support page: https://dragonsoul.zendesk.com/hc/en-us
iii Data Protection Officers（DPO）
Company elected the data protection officer is involved, properly and in a timely manner, in all issues which relate to the protection of personal data.
Data Protection Officer GREE, Inc.
Roppongi Hills Mori Tower, 6-10-1 Roppongi, Minato-ku, Tokyo,
iv Controller of your personal information and its contact Fantasy Legend Studio, Inc.
185 Berry Street, Suite 590 San Francisco, CA 94107
5. Administration Policy
ii Retention Policy
Except as the case being necessary for the compliance of applicable law, regulation or order by the government, court or other applicable authority, the personal data will be deleted within three years after this App has closed.