PUZZLE & DRAGONS

GUNGHO ONLINE ENTERTAINMENT, INC.
U.S. PRIVACY POLICY

Effective Date: September 26, 2024

GungHo Online Entertainment, Inc., a Japanese corporation or one of its wholly owned subsidiaries, joint ventures or affiliates (“Company,” “our,” or “we”) owns and operates this website (our “Website”). We respect the privacy of users of our Website (“you” or “your”) and have adopted this Privacy Policy (this “Policy”) to explain what information we collect from or about you through our Website and how we use, maintain, protect, and disclose that information.

Please read this Policy carefully to understand our policies and practices regarding your information. By accessing or using our Website, except where prohibited, you agree to this Policy, which is incorporated into our Terms of Service (gungho.jp). If you do not agree to this Policy, you may not use our Website.

1. General Policy.

We respect your privacy and are committed to protecting your “Personal Data,” which we define as information relating to an identified or identifiable individual like you. Personal Data does not include aggregated or anonymized information, provided it does not and cannot identify you. This Policy applies only to information we collect through our Website. Except where otherwise noted, it does not apply to information we collect through other channels. It outlines what Personal Data we collect about you through our Website and how it is used. It also explains how we process your Personal Data, who we share it with, how we look after it, and tells you about your privacy rights and how the law protects you.

2. Supplemental Privacy Notices.

In addition to the provisions in this Policy, which are generally applicable across all jurisdictions, if you are resident in one of the following locations, please review the applicable supplemental privacy notice (each a “Supplemental Privacy Notice”) linked below.
・LINK: Supplemental U.S. Privacy Notice

3. What information do we collect about you?

We collect information about our customers, prospective customers, vendors and business partners, and Website visitors. The type of Personal Data we collect depends on the nature of our relationship with you and the legal requirements in your location. We endeavor to collect only information that is relevant for the purposes of processing. The table below sets out the various categories of Personal Data that we may collect.

CATEGORY OF PERSONAL DATA	REPRESENTATIVE DATA ELEMENTS	INDIVIDUAL TO WHICH DATA APPLIES
Contact Information	・Name ・Postal address ・Telephone number ・Email address	・Vendors, customers and other partners
Unique IDs	・Device identifier ・Cookie ID	・Vendors, customers and other partners ・Website visitors
Financial Information	・Bank account number and details ・Payment card information ・Payment and reimbursement amounts	・Vendors, customers and other partners
Website Activity Information	・Browing and search history ・Referring website addresses ・App usage data ・Device characteristics	・Vendors, customers and other business partners ・Website visitors

・Personal Data of Minors. We do not knowingly collect, store, process, sell or share information from minors under the age of eighteen (18) years except as required by applicable laws.

・If we become aware or you or your parent/legal guardian identify to us or one our third party partners, that you are a minor under the minimum age of consent guidelines set by applicable laws, we will:

(a) Promptly obtain verifiable consent from your parent or legal guardian for the use your Personal Data, when required by applicable laws; and

(b) offer controls and choices to parents and legal guardians. For example, if your parent or legal guardian wishes to revoke their previously provided consent, we will provide them with an opportunity to review information collected from you or have that information deleted by contacting us via the process described in this Policy. If we become aware that you have provided us with Personal Data without verifiable consent as required by applicable law, we will delete any Personal Data we have collected, unless we have a legal obligation to keep it, and terminate your account and/or revert you to the age-appropriate experience, as applicable. If we make material changes to how we collect, store, use, sell, share or otherwise process Personal Data of minors under the minimum age of consent guidelines set by applicable laws, we will update this Policy accordingly and if applicable, notify such minor’s parents or legal guardians as required by applicable law.

4. How do we collect your information?

We collect Personal Data directly from you and from other sources. The table below sets out the most common sources of Personal Data.

SOURCES OF PERSONAL DATA	REPRESENTATIVE COLLECTION METHODS AND CIRCUMSTANCES
Directly from you	・When you submit information through a survey or contest-entry form ・When you post a comment or feedback on our Website ・When you contact us
Through automated means	・Automatically collected as you navigate our Website
From third parties	・Marketing analytics service providers so that we can better understand our customers ・Website analytics firms that help us improve our Website ・Data aggregators from which we receive supplemental information about our customers ・Through your interactions with third-party social media platforms ・For vendors and business partners: In the course of due diligence prior to contracting with you, in order to comply with regulatory requirements

5. How do we use your information?

We only use Personal Data when the law allows us to do so. We use Personal Data for the following purposes. To:

・Provide the information, products, and services you request;
・Provide you with effective customer service;
・Respond to your inquiries;
・Provide you with additional features on the Website based on your location;
・Send you transactional and administrative messages related to our products;
・Send you marketing communications (in accordance with your preferences);
・Invite you to participate in surveys and provide feedback to us (in accordance with any preferences you expressed to us);
・Improve the content, functionality, security and usability of our Website;
・Create insights and market intelligence (on an aggregated and non-personally identifiable basis) through analyzing the use our Website and our customers;
・Provide advertisements and monitor their effectiveness;
・Monitor security and prevent fraud;
・Comply with our legal and regulatory obligations.
・Meet other purposes notified to you through our Website, an applicable agreement or another channel.

6. What is the legal basis for our data collection?

We collect Personal Data about you for a variety of purposes based on the specific legal grounds described in the table below, unless your jurisdiction requires a special legal basis for the collection of personal data (for example, consent). Please refer to the Supplemental Privacy Notice applicable to your jurisdiction for additional information.

PURPOSE FOR COLLECTION	LAWFUL BASIS
Delivering information, content, products or services that you request or purchase	・To perform a contract or fulfill our obligation to provide products or services to you ・Our legitimate interests
Provide marketing communications about our products and services, or those of third parties, that may be of interest to you	・Your consent ・Our legitimate interests
Understanding how you use our products, services, and Website in order to improve and further develop our products and services and the content, features, performance, and support available through our Websites	・Our legitimate interests
Providing legal or service-related notices about our products, services, and Websites	・To perform a contract with you ・Our legitimate interests ・To comply with a legal obligation
Detecting, preventing, and responding to fraud, intellectual property infringement, violations of our Terms of Service (gungho.jp), violations of law, or other misuse of the Websites	・Our legitimate interests ・To comply with a legal obligation
Protecting our rights or the rights, property, and safety of others	・Our legitimate interests ・To comply with a legal obligation
Complying with laws and regulations, judicial and administrative orders, or lawful requests from governmental authorities	・To comply with a legal obligation
Conducting due diligence prior to entering into a contract with you	・Your consent ・To perform a contract with you ・Our legitimate interests
Processing your application for employment with us, including administration of the recruitment process and evaluation of your candidacy	・Your consent ・To perform a contract with you ・Our legitimate interests ・To comply with a legal obligation
Paying you for services you have provided to us, providing you with benefits to which you are entitled, or reimbursing you for expenses	・To perform a contract with you

We may combine or aggregate any Personal Data we collect for any of the above purposes.  We may also anonymize your Personal Data in such a way that you may not be re-identified by us or any other organization. We may use such anonymized information for any purpose.

7. When do we share your information?

We share your Personal Data with third parties for the purposes listed below.

CATEGORY OF THIRD PARTY	REPRESENTATIVE PURPOSES FOR DISCLOSURE	SAFEGUARDS
Our wholly owned subsidiaries , GungHo Online Entertainment America, Inc. (“GungHo America”)	・GungHo America is required to comply with this Privacy Policy	・GungHo America is required to comply with this Privacy Policy
Service providers (contractors, professional advisors, insurers, finance providers or external auditors)	・To assist us in the functions and activities described above concerning the purposes for which we collect your Personal Data, including: - IT support, cloud platform and data hosting services to support the operating of our websites, mobile applications, document and workflow management systems and other systems and applications. - Payment processing. - Assistance with supply chain logistics and delivery of products you have requested/ordered. - Customer service activities, including managing queries and complaints. - Marketing support, including sending out email and other communications on our behalf. - Record-keeping and reporting to assist us in complying with laws and industry standards.	・We execute contracts with service providers prohibiting them from using or sharing your Personal Data except as necessary to perform the contracted services on our behalf or to comply with applicable legal requirements
Marketing Partners	・To jointly offer products or services	・We execute contracts with business partners that requires them to protect your Personal Data, and, where required by applicable laws, your Personal Data is only shared with your explicit consent.
Successor-in-interest (actual or proposed)	・To continue to perform the functions and activities described above concerning the purposes for which we collect your Personal Data in the event of a proposed actual purchase, any reorganization, sale, lease, merger, joint venture, assignment, amalgamation, or other type of acquisition, disposal or financing of all or any portion of our business or any of the business assets or shares (including in connection with any bankruptcy or similar proceeding).	・We will endeavor to direct the transferee to use Personal Data in a manner that is consistent with this Policy.
Regulatory authorities and law enforcement agencies	・Where necessary for any investigations or to respond to inquiries in relation to our compliance with applicable laws or regulations. ・Where we, in good faith, believe disclosure is appropriate to prevent or investigate a possible crime, or to protect the security of our personnel or property, or the personnel or property of others.	・We endeavor to limit such disclosures to the minimum necessary and to obtain assurances that your Personal Data will be protected.
Judicial authorities and parties to judicial proceedings	・To respond to a court order or other binding request	・We endeavor to limit such disclosures to the minimum necessary and to obtain assurances that your Personal Data will be protected.

・We do not sell your Personal Data.
Nor do we share your Personal Data with third parties for their own marketing purposes, except with your consent and in connection with a jointly offered product or service.

・Personal Data Disclosure.
We may disclose your Personal Data to anyone to whom disclosure is necessary to fulfill the purpose for which you provided the Personal Data.

・Aggregated Information.
We share aggregated information about our users (e.g., statistical or demographic data) for any purpose. Such information could be derived from your Personal Data, but it no longer identifies you directly or indirectly. For example, we may aggregate usage data to calculate the percentage of users accessing a specific Website feature. However, if we combine or connect aggregated information with your Personal Data so that it can directly or indirectly identify you, we treat the combined information as Personal Data which will be used in accordance with this Policy.

・User Contributions.
Content you post to the Website or in interactions with us through Facebook, Instagram, X (formerly known as Twitter), and other social networking platforms we make available to you (collectively, “User Contributions”), including those that contain Personal Data, are publicly accessible. In particular, please note that User Contributions, by definition, can be read, collected, used, and further disclosed by other users of our Website or social networking platforms. Please refer to our Terms of Service (gungho.jp) for more information about User Contributions. We strongly recommend you avoid sharing any personal details, and especially information that can be used to identify you directly such as your name, age, address and name of employer, in your User Contributions. We do not control how third parties who may access this publicly accessible information may use your User Contributions. We may use User Contributions for advertising campaigns and other promotions, and we share User Contributions with third parties for such purposes. Where such advertising campaigns or promotions involve Personal Data connected to your User Contribution, we will seek your consent before using the information.

・Links to Other Websites.
Our Website may contain links to third-party websites or other online platforms. Clicking on these links may allow third parties to collect or share information about you. These links are provided for your reference and convenience only and do not imply any endorsement of the products sold or information provided through these websites, nor any association with their operators. We do not control these websites and we are not responsible for their data practices or privacy statements. Any information you provide to third parties on their websites is covered under their privacy and data collection policies and is not covered by this Policy. We urge you to review the privacy policy posted on any website you visit before using the website or providing any personally identifiable information.

・Social Media Platforms.
Facebook, Instagram, X (formerly known as Twitter), and other social media platforms provide tools that many of our customers use and enjoy, and we include links to various social media platforms on our Website. If you interact with these social media platforms through our Website, including with our profiles on these platforms, your experience on those platforms will be governed by the privacy and other policies of those platforms. We encourage you to choose your privacy settings on those websites accordingly. If you log into our Website using your credentials from a social media platform, that platform also may receive data about the pages or content that you viewed on our Website.

・Third-Party Analytics Tools.
Beyond the information you voluntarily provide to us directly, we utilize analytics tools, including third-party technologies such as Google Analytics, to collect information and help us understand how visitors engage with our Website. To learn more about Google Analytics, click here. To learn more about how Google uses data collected through partner websites or applications, click here.

・Cookies.
We use cookies, web beacons, and similar tracking technologies (collectively, “cookies”) on our Website. Cookies are small amounts of data that are stored on your browser, device, or the page you are viewing. Some cookies are deleted once you close your browser, while other cookies are retained even after you close your browser so that you can be recognized when you return to a Website. You can find more information about cookies and how they work at www.allaboutcookies.org and www.youronlinechoices.com. Cookies on our Website are generally divided into the following categories:

- Essential Cookies: These cookies are essential in order to enable you to move around our Website and use its features, such as accessing secure areas of our Website.

- Analytical / Performance Cookies: These cookies include Google Analytics and they keep track of the pages that you visit and content you access, so we can tailor our Website to our users’ needs and improve the performance of our Website.

- Functional Cookies: These cookies remember the choices you make, such as language options or the region you are in. These cookies personalize your experience when you use our Website.

Generally, the information we collect using these cookies does not identify you personally. If, however, you have created a user identity, for example, by subscribing to our publications or filling out forms, we may link the information we collect using cookies to other information that identifies you personally. If you do not wish to receive cookies, you may set your browser to reject cookies or to alert you when a cookie is placed on your computer. You may also delete our cookies as soon as you leave our Website. Although you are not required to accept our cookies when you visit this Website, you will not be able to use all of the features and functionality of our Website if you set your browser to, or manually reject cookies.

・Third-Party Advertising Tools.
Third parties may deliver cookies or other tracking technologies, including web beacons or tracking pixels, to your computer or mobile device for the purpose of tracking your online behaviors across nonaffiliated websites, and to deliver targeted advertisements on other nonaffiliated websites.

8. Where do we process your information?

Your Personal Data may be stored and processed in your country, but it may also be transferred to or viewed in another country, including the U.S. and Japan, where allowed by applicable laws. We are part of a global company, and we may transfer your Personal Data in compliance with applicable laws to a recipient in another jurisdiction, or receive your Personal Data from another jurisdiction, if one of the following protections applies:

・The recipient is located in a jurisdiction in which the laws ensure a level of data protection that is equivalent to those in jurisdiction where data was collected.
・The recipient is subject to an approved certification mechanism or code of conduct with binding and enforceable commitments that provide appropriate safeguards for your Personal Data.
・We have put in place appropriate contractual safeguards to protect your Personal Data.
・The transfer to a foreign jurisdiction is expressly permitted by applicable laws.
・You explicitly consent to the transfer.

9. How do we secure your information?

We have put in place reasonable security measures to prevent your Personal Data from unlawful or unauthorized processing and accidental loss, destruction, alteration or damage. Unfortunately, the transmission of information via the internet can never be completely secure. Subject to applicable law, we disclaim any guarantees, warranties or representations relating to maintenance or nondisclosure of any transmitted Personal Data.

・Data Retention.
We will retain your Personal Data for as long as is necessary for the purposes listed in this Policy unless a longer period is required under applicable law, or a longer period is needed to resolve disputes or protect our legal rights or otherwise comply with legal obligations. When assessing the data retention period, we take into account the amount, nature, and sensitivity of the information, the potential risk of harm from unauthorized use or disclosure of the data, the purposes for which we process the data and whether we can achieve those purposes through other means, and the applicable legal requirements.

10. What are your legal rights?

In certain circumstances, you have rights under data protection laws in relation to your Personal Data. Your rights may vary depending on the country in which you live, or the country in which we process your information. Please refer to the appropriate Supplemental Privacy Notice that is applicable to you for rights specific to your location. If you wish to exercise any of the rights set forth in the applicable Supplemental Privacy Notice, please review the process described therein, or to learn more about such rights, please contact us as indicated below.

11. How can you update your information?

Please contact us as indicated below.

12. How can you change your marketing preferences?

・In General.
We respect your right to make choices about the ways in which we collect, use, and disclose your Personal Data. We may ask you to indicate your choices at the time and on the page where you provide your information. Our Cookie Policy set forth above describes additional choices, such as your choice to opt out of receiving “cookies.”

・Opt-in or Opt-out Mechanism.
In relation to marketing communications (including promotional emails) we may send you, we may provide you with an “opt-in” or “opt-out” mechanism depending on where you are located. An “opt-in” mechanism will provide you the opportunity to positively indicate that you agree to our sending you such further communications. An “opt-out” mechanism will provide you the opportunity to indicate that you do not want us to send you such further communications, and if you “opt-out” we will not send you any additional such communications.

・Email preferences.
You can opt out of promotional emails we may send you. If such promotional emails are sent to you and you wish to stop receiving such emails, simply select “unsubscribe” located at the bottom of each communication. Please note that you cannot opt out of transactional emails, such as emails confirming a purchase made on our Website.

・Previously Expressed Preferences.
You may be able to change previously expressed preferences regarding how we use your information. To do so, please contact us using the contact information provided below.

13. Changes to this Policy.

We are continually improving and adding to the features and functionality of this Website, and to the services we offer through this Website. As a result of these changes (or changes in the law), we may need to update or revise this Policy. Accordingly, we reserve the right to update or modify this Policy at any time, without prior notice (unless prohibited in your jurisdiction), by posting the revised version of this Policy behind the link marked “Privacy Policy” at the bottom of each page of this Website. Your continued use of this Website after we have posted the revised Policy constitutes your agreement to be bound by the revised Policy. However, we will honor the terms that were in effect when we gathered data from you. We will also endeavor, where feasible, to notify you in advance of significant and material changes to this Policy. For your convenience, whenever this Policy is changed, we will update the “Revised on” at the top of this page. Be sure you check the “Revised on” date to see if this Policy has been revised since your last visit.

14. Terms of Service.

This Policy and any applicable Supplemental Privacy Notices are incorporated into the Terms of Service (gungho.jp) that govern your use of this Website. If you do not agree to abide by the Terms of Service (gungho.jp) you may not access or use this Website.

15. Severability.

If any provision of this Policy, including a Supplemental Privacy Notice, is declared invalid or unenforceable by a court having competent jurisdiction, that provision will be removed from the Policy without affecting the rest of the Policy, and the remaining provisions of the Policy shall continue to be valid and enforceable.

16. Contact Details.

If you have any questions about this Policy or our privacy practices, please contact us at GungHo Support.

GungHo Online Entertainment, Inc.
Pacific Century Place Marunouchi, 1-11-1 Marunouchi, Chiyoda-ku, Tokyo, 100-6221 Japan