- Privacy Policy
- Effective Date: April 14, 2021
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A PLUS JAPAN Inc. (“APLUS”, “we”, “our”, or “us”) greatly recognizes and values the privacy of people (“you” or “User”) who visit our websites, use or access our games, whether played on mobile devices, PCs, our websites or other approved platforms (“APLUS Game(s)”), and/or otherwise use or access any of our provided services, including but not limited to customer support, marketing and advertising, and community services (collectively the “APLUS Services” or “our services”).
This Privacy Policy applies to any and all of the APLUS Services and describes why and how we collect, store, and use your personal data, and the choices and rights you have about the personal data you provide or we collect in connection with the APLUS Services. By accessing our websites or otherwise using the APLUS Services, you acknowledge that you have read, understood and accepted the following terms. In the case you do not agree to any of the terms, some basic functions in the APLUS Game(s) may not be able to run normally, which may prevent you from using them.
- Table of Contents
- THE DATA WE COLLECT AND PROCESS
- THE REASON WHY WE COLLECT YOUR DATA
- WHO MAY ACCESS YOUR PERSONAL DATA
- HOW DO WE PROTECT YOUR DATA
- YOUR RIGHTS AND OPTIONS
- COOKIES AND SIMILAR TECHNOLOGIES
- AGE LIMITS AND CHILDREN PROTECTION
- INTERNATIONAL DATA TRANSFERS
- FOR CALIFORNIA RESIDENTS
- EU-U.S. PRIVACY SHIELD
- GOVERNING LAW AND JURISDICTION
- UPDATES TO THIS POLICY
- CONTACT US
- THE DATA WE COLLECT AND PROCESS
- The categories of personal data we collect depend on the Services you use, and the requirements of applicable law.
- Data you provide us directly.
- Account Registration Information: username, email address, password, and verification code.
- Date of Birth. We only receive this information if you voluntarily provide it when using our services, and we use this information to verify your age if you are a user in certain regions.
- Telephone Number or Email Address. We only receive such information if you voluntarily provide it to us for linking your Account with your telephone number and/or email address, logging in to our services, receiving updates of our services and receiving verification codes by email or SMS for password changing or other purposes.
- User Generated Content: Nickname, signature, and chat data (solely in the form of text).
- User Service Information. Any information that you provide in communications with our support team when you seek our technical and/or customer service support and/or exercise any of your legal rights as the data subject.
- Sweepstakes Participation Information: Name, email address, telephone number, mailing address, UID, nickname, and country/region.
- Internet Protocol (IP) Address.
- Other data you choose to give us (such as data you provide to participate in promotional programs)
- Unless obtaining your express and additional consent in advance and for specific circumstances, we will not collect personally identifiable information (PII) or sensitive personal information (SPI), such as real name, address, and/or fax number. You acknowledge and agree that if you elect to submit any personal data, such personal data would be subject to this Privacy Policy and you agree with all the terms therein. Please note that any personal data submitted in business transactions will not be subject to this Privacy Policy, including but not limited to job applications, participation in events, and contract signings.
- Data we collect automatically.
- Generated Open ID.
- IP Address.
- Game Data.
- Device Related Information. Device ID, device information (device name, device type, MAC address, IMEI, CPU, graphics card model, OS version and language, time zone, screen DPI, device resolution), registration time and login time.
- Bugs, Errors, and Other Data About Crashes and Diagnosis Thereof (if the occasional system crash occurs in our services). Device information (name, model, memory size, and graphics card model) and in-game information (game version, user's UID, stacktrace).
- Security-Related Information. For the Android version: application information (APK name, version, startup time, process name), user account, device information (model, OS version, brand, CPU structure, root status, the unique identifier of ROM, screen resolution, system startup time, whether an emulator is being operated, the installed APK information, MAC address, network type, names of the running applications, list of file names in the cache directory of SD card application, and Wi-Fi name); for the PC version: application information, memory, executable module, system driver module, new thread, new load module, proxy, network, CPU, disk, and graphics card, account information, and device name, specific file types for specific directory, names of process windows, and name signature of suspicious process module; for the iOS version: application information (module and signature), root status of device.
- Malicious Content Information. Nickname, signature, chat data (solely in the form of text).
- Approximate location data (as derived from IP address)
- Data we collect from our partners.
- We also use third-party partners, such as social networking sites, data analytics providers and advertising networks to supplement information we have about you, such as:
- Connected Social Media Account Information (Third-Party). Your social media account information (if you choose to log in to our services via your social media account(s) with the corresponding network(s)).
- Demographic data (such as to determine the coarse location of your IP address)
- Data to fight fraud (such as refund abuse in games or click fraud in advertising)
- Data from platforms that the games run on or data from payment service providers (such as payment verification data)
- Data for advertising and analytics purposes (such as surveys), so we can provide you a better Service
- Data that you have made available to us from a third party service (such as LINE, Facebook, WeChat or Kakao) via your privacy settings
- When you use or interact with third-party services that may be available on our services, such as third-party social media widgets, share buttons, and/or login mechanisms, this Privacy Policy does not and will not extend to such features, which shall be subject to the respective third-party privacy policies.
- WHY DO WE COLLECT YOUR DATA
- In order to provide services, perform the Terms of Service and/or any other agreements between you and APLUS, and/or perform the legal liabilities under the applicable laws, we collect and process your personal data to:
- allow you to access or restrict your access to our services;
- analyze and manage our services for system administration, user service, security, fraud-detection, checking the authenticity of an account owner, archival and/or backup purposes;
- correct bugs or errors, improve our services and respond to customer desires and preferences, including language and location customization, personalized support and instructions, and other responses;
- develop new services or products that user(s) request and improve the user experience;
- verify and confirm payment;
- deliver advertising that may be relevant to your interests (you can choose to turn this feature on or off in the device settings as stated hereunder);
- communicate with other users and take action against violations;
- personalize your experience, keep you up to date with the latest product announcements, provide software verification, upgrades and administration, notify of special events, offer to participate in our surveys or activities, and provide other information pertaining to our services;
- protect the integrity, safety, and security of our services or users, comply with legal obligations, and enforce compliance with the Terms of Service or other restrictions placed on your use of our services; and/or
- track your process across our websites and applications to verify that you are not a bot and to optimize our services.
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In all of the above cases and purposes, you acknowledge and confirm that we may analyze, profile, segment, merge and/or update all collected data (regardless of an aggregated or individualized manner) for the purposes of improving service quality and providing a better experience.
In specific cases, we may collect other personal data apart from the categories stated herein based on your consent. When this occurs, we will, upon requiring your additional consent, provide more information about any change to the way or purpose of our collection or processing which might be different from or not clarified in the details in this Privacy Policy.
- WHO MAY ACCESS YOUR PERSONAL DATA
- In addition to APLUS and/or its affiliates, other parties may also access your personal data in the following situations. You acknowledge that you have foreseen and agreed to the occurrence of such disclosure when you provide your personal data.
- Other in-game users of our services.
- Other users may, for example, in a group challenge, access your in-game activities in the process of such group challenge. Other users may also see your displayed data and read the messages you have posted on or through our services. You acknowledge and agree that our services may also include message boards, communities, forums, and/or other chat areas, where users may exchange ideas or communicate with other users, and that any data you post to any communication area is publicly viewable. We strongly recommend that all users avoid posting personal or sensitive data at any time on or through our services.
- Competent authorities
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We may provide a certain portion of your personal data to judicial or administrative authorities as so requested. Besides, we may disclose certain portion of your personal data within a strictly limited scope of recipients when we reasonably think it is necessary to protect us, our users or a portion of the public.
In addition to be required by applicable laws, we reserve the right to disclose your personal data in the cases if we, in our good faith, believe that disclosing such data is necessary to identify, contact, or bring legal action against you, if (a) you are violating any other agreement(s) between you and us, such as the Terms of Service, this Privacy Policy or otherwise damage us; (b) you are infringing third-parties’ rights and interests (including but not limited to intellectual property rights); and/or (c) we believe that it is necessary to prevent fraud or other illegal activities.
- Third-party contractors
- APLUS works with a number of (if any) third parties on or through our services to help us provide services and functionalities to you. We do not sell your personal data and only share data that is non-personally identifiable on its own, aggregated, or public with third-parties under the following necessary circumstances, and such third-parties thereof are prevented from processing (including but not limited to accessing, storing, using, or disclosing) your personal data except for achieving the purpose of their cooperation with us:
- Social networking portals who provide login and/or content-sharing service to and in our services;
- Logistics service providers who provide shipping services such as delivering physical prizes to users;
- Information communication service providers who provide SMS-messaging services;
- Payment service providers who provide payment services, such as assisting our services to run on, facilitating users’ payment, and maintaining a record of the users’ transaction history;
- Advertising service contractors who provide marketing and advertising activities, including conducting the programs, tracking the success, and analyzing the effect thereof; and
- Other contractors if any for the purpose of providing our services to you.
- Besides, such contractors may use cookies, web beacons, and/or other tracking technologies to collect or receive data about you and might claim the data controller rights over your personal data. Each third-party has its own privacy policy and security measures for processing data and information, so when specific third-parties are involved in collecting data and information, please participate in their privacy policies. Since those contractors may access, collect, or process your data as the data controller and operate under their own privacy policies, please refer directly to their privacy policies on their official websites and learn more about their data processing practices.
- HOW DO WE PROTECT YOUR DATA
- Security Safeguards.
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Pertaining to your use of our services, we have endeavored to take reasonable measures to prevent unauthorized access to or improper use of your personal data, such as organizational controls, technical protection and other protection measures.
Unfortunately, the transmission of information via the internet is not completely secure. While we strive to protect your personal data, we also remind you to be aware of hacking, cyber-attacks, and other risks on the Internet.
Therefore, we strongly urge you to take every possible precaution to protect your personal data when using our services, including but not limited to changing your passwords from time to time, not reflecting your real name or other personal data in registration, using a combination of letters and numbers when creating passwords, using a secure browser and/or taking other possible security measures. Please note that for security reasons, we store passwords in encrypted form.
Please be aware that advertisers or websites with links to and/or from our websites may collect personal data about you and this Privacy Policy does not apply to, and cannot control the activities of, those other advertisers or websites. We highly recommend that you read the privacy policy of such third-party websites which you may be directed to before providing any personal data.
You acknowledge and agree that your data will be processed on our servers which may not be located in your country of residence and can be accessed by our support, engineering and/or our affiliates around the world. No matter where our servers are located, we will make great efforts to take the appropriate safeguards to guarantee your rights in conformity with this Privacy Policy and any applicable laws.
- Data retention.
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We will keep your data only for as long as your account is active or only for as needed to provide you the APLUS game services unless deleted in accordance with your request or as otherwise required by law.
In the case you request to remove or delete your personal data, we will retain your data as long as necessary for our legitimate business interests, such as to comply with our legal obligations, resolve disputes, and/or enforce the agreements between you and us. Please note that the removal or deletion of any of your data may result in the termination of some of our applicable services.
We will only store your information as long as necessary to fulfil the purposes for which the information is collected and processed or where the applicable law provides for longer storage and retention period. Upon the expiration of such period, your personal data will be deleted, blocked or anonymized, as provided by applicable law.
- YOUR RIGHTS AND OPTIONS
- Right to access the personal data we hold about you
- If you request, we will provide you a copy of your personal data in an electronic format.
- Right to rectify
- If your personal data is inaccurate or incomplete, you have the right to obtain rectification of your inaccurate personal data without undue delay according to Article 16 of the GDPR and you can modify the information you provided via the privacy dashboard.
- Right to request deletion of personal information
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You have the right to obtain deletion of your personal data, if the reason as stated in Article 2 of this Privacy Policy does not exist anymore, or if there is another legal ground for its deletion, subject to submitting a verifiable request in the form of sending an email to us.
You acknowledge and agree that as a result of deleting your APLUS account, you will lose access to APLUS’s services, including the APLUS account, subscriptions and game-related information linked to such account and lose the possibility to access other services through the APLUS account.
- Right to object
- When our processing of your personal data is based on legitimate interests according to Article 6(1)(f) of the GDPR and/or Article 2 of this Privacy Policy or any other applicable laws in your country of residence, you have the right to object to our processing. If you object, we will no longer process your personal data unless there are compelling and prevailing legitimate grounds of processing as described in Article 21 of the GDPR or any other applicable laws in your country of residence.
- Right to restrict processing
- You have the right to restrict the processing of your personal data under the conditions set out in Article 18 of the GDPR or any other applicable laws in your country of residence.
- Right to opt-out of marketing emails and other direct marketing.
- You may opt-out of receiving promotional communications, such as marketing emails from us by following the instructions in such communications, or by changing your in-game settings. The updated settings may not be effective immediately. Note that you may still continue to receive non-promotional communications from us, such as communications regarding the Service or updates to our Terms of Service or this Privacy Policy.
- Right to opt-out of Push Notifications
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We may send you push notifications through our mobile applications. You may at any time opt-out from receiving these types of communications by changing the settings on your mobile device.
You can also opt out from personalized in-game offers through the options provided in the game settings.
- COOKIES AND SIMILAR TECHNOLOGIES
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In order to measure the effectiveness of our services, We may use cookies and/or authorize a third-party’s tracking-utility, from time to time, (a) to log your IP address in determining the path that users take on our sites and identifying repeated users of our sites, (b) to collect the websites or sources that linked or referred you to our services, and/or (c) to collect technical data about the devices and software you use to access our services, the operating system of your devices, and other similar technical data. Notwithstanding the foregoing, we do not link your IP address to your personal data. If you do not wish to accept cookies or want to be notified of when they are placed, you may set your web browser to do so, if your browser permits.
We use the cookies, web beacons and similar technologies to personalize your experiences on our services and for various other purposes, including:
- remembering you: cookies, web beacons and similar technologies help us identify you as a registered user and keep the preferences or data that you have previously provided;
- analyzing how you use our services: cookies, web beacons and similar technologies help us understand what visitors (including users) are doing on our services, or what pages or sections are most popular;
- deliver advertising: cookies, web beacons and similar technologies help us provide you with advertising that we believe is relevant to you or of interest to you, on the basis of the data you provide; and/or
- other related functions or purposes mentioned in Article 2 herein.
- We or our authorized contractors may use cookies and similar technologies to provide and personalize services, prevent fraud and fulfil other purposes mentioned above. Please note you can disable cookies in your browser settings, while some parts of our services may then not function properly.
- AGE LIMITS AND CHILDREN PROTECTION
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You represent that you are an adult or older in your country of residence (or at other age in your jurisdiction where you are classified as a majority) when using our services. If you are a minor child or under the legal age of majority (“Minor” or “Children”), please do not send any personal data about yourself to us, including your name, address, telephone number, or email address.
Notwithstanding the foregoing, we recognize that we have a special obligation to protect children in regards to the collection and processing of personal data, and we do not and will not knowingly collect personal data from children without consent from their parents or guardians. We strongly urge parents and guardians to instruct their children never to disclose or give out their personal data when using our services without the prior permission of their parent/guardian. If we learn that we have collected personal data about a child, we will delete that data as quickly as possible. Also, if you believe that we might have any data from or about a child, please contact us.
- INTERNATIONAL DATA TRANSFERS
- We may transfer information that we collect about you to affiliated entities, or to other third parties across borders and from your country or jurisdiction to other countries or jurisdictions around the world. Please note that these countries and jurisdictions may not have the same data protection laws as your own jurisdiction, and we take steps to ensure adequate safeguards are in place to enable transfer of information and the use and disclosure of information about you, including personal information, as described in this Policy.
- FOR CALIFORNIA RESIDENTS
- The California Consumer Privacy Act (“CCPA”) grants California residents certain privacy rights regarding personal data we collect. We are committed to respecting these rights and complying with the CCPA.
- EU-U.S. PRIVACY SHIELD
- APLUS complies with the EU-U.S. Privacy Shield Framework as set forth by the U.S. Department of Commerce regarding the collection, use, and retention of personal data transferred from the EU to the United States. If there is any conflict between the terms in this Policy and the Privacy Shield Principles, the Privacy Shield Principles shall take precedence.
- CONTROLLING LAW AND JURISDICTION
- This policy and any action related thereto will be governed by the laws of People’s Republic of China without regard to its conflict of law’s provisions. Any dispute arising from or in connection with this Policy shall be submitted to Hong Kong International Arbitration Center ("HKIAC") for arbitration, which shall be conducted in accordance with HKIAC 's arbitration rules in effect at the time of applying for arbitration. The seat of arbitration shall be Hong Kong. The language to be used in the arbitral proceedings shall be Chinese. The arbitral award is final and binding upon both parties.
- UPDATES TO THIS POLICY
- In the event of a merger, acquisition, reorganization, bankruptcy or other similar event, we will make an announcement in advance, disclose the details of the event and information about the successor, and with the express consent of you and/or your parent and/or guardian (if applicable) again, your personal data may transfer to the successor of APLUS. APLUS may periodically modify, adjust or revise the terms of this Privacy Policy. We will announce to you the updated terms and obtain your consent (and/or the consent of your parent/guardian, if applicable) again. You acknowledge and agree to check the updated terms regularly. If major clause changes are involved, we will make an announcement in advance.
- CONTACT US
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If you have questions about data protection, or if you have any requests for resolving issues with your personal data, we encourage you to primarily contact us through the support features within each APLUS game, so we can reply to you more quickly. Alternatively, you may contact:
Name of the controller: [SUSUMU TANAKA]
Address: Toranomon Hills Mori Tower 8F 1-23-1 Toranomon, Minato-ku, Tokyo Attn: Privacy
email: [herosupport@aplusjapan.co.jp ]