Privacy Policy

1. Basic Policy on Personal Information Protection

NTT Solmare Corporation (hereinafter referred to as “the Company”) fully recognizes societal demands for the protection of personal information and believes that promotion of the proper handling of personal information is an important social responsibility it must fulfill.

In order to fulfill this responsibility and continue operating as a company with high credibility, the entire Company will strive to protect personal information based on the “NTT Group Information Security Policy” and the basic policy outlined below.

  • (1) The Company will strive for thorough compliance by properly handling personal information according to the provisions stipulated by laws and regulations*1 pertaining to the protection of personal information.
  • (2) The Company will clearly define the purposes for which it uses personal information and properly handle personal information to the extent necessary to achieve those purposes of use. In addition, the Company will strive to keep personal information accurate and updated.
  • (3) In order to properly manage personal information, the Company will establish an internal management system for protecting personal information.
  • (4) The Company will conduct necessary education, training, etc. for its employees who handle personal information in the course of work, and supervise those employees appropriately. In addition, in the case of outsourcing the handling of personal information, the Company will manage and supervise the relevant subcontractor by entering into a confidential agreement, etc. with the subcontractor to ensure that personal information is properly handled.
  • (5) In order to ensure personal information security, the Company will take the necessary security control measures while referring to various standards, guidelines, etc.
  • (6) The Company will appropriately respond to opinions, questions, etc. from customers pertaining to the handling of personal information by the Company.
  • (7) In order to promote greater protection of personal information, the Company will strive to continuously improve the management system, security control measures, and other necessary measures.
  • *1 Examples of laws, regulations, etc. related to the protection of personal information- (Unless otherwise specified, the laws and regulations are those of Japan.)
    • – Act on the Protection of Personal Information (Act No. 57 of 2003; hereinafter referred to as the “Personal Information Protection Act”)
    • – Act on the Telecommunications Business (Act No. 86 of 1984)
    • – Guidelines on the Protection of Personal Information in the Telecommunications Business (Ministry of Internal Affairs and Communications Public Notice No. 695 of 2004)
    • – Policy on Measures to be Implemented by Companies to Secure the Proper Handling of Personal Information in Employment Management (Ministry of Health, Labor and Welfare Public Notice No. 259 of 2004)

2. Policy concerning the Practical Use of Personal Information

  • (1) Purposes of Use
    With regard to personal information (personal information as defined in Article 2 of the Personal Information Protection Act; hereinafter the same meaning shall apply.)*2 handled in connection with the provision, sale, etc. of information-providing services or digital content delivery services, etc., the Company specifies the purposes of use as follows.
  • *2 Personal Information
    With regard to customers other than individuals, this personal information Includes personal information on the representatives, officers, employees, etc. of those customers that is used by Company in providing, selling, etc. information-providing services or digital content delivery services, etc. Hereinafter the same meaning shall apply.

    • (i) The personal information below, that is, information the Company handles when customers order, use, or make inquiries about information-providing services or digital content delivery services, etc., will be used to the extent necessary for verifying the identities of customers, controlling credit, providing information-providing services or digital content delivery services, etc., calculating and invoicing charges for information-providing services or digital content delivery services, etc., and making contact with customers in relation to the above, etc.In addition, the information will be used to the extent necessary to introduce and propose information-providing services and digital content delivery services, etc., implement measures to improve and enhance quality and customer satisfaction, etc. (including questionnaires), plan and develop new information-providing services or digital content delivery services, etc., manage and improve facilities related to the provision of the services, and conduct any other business related to the information-providing services or digital content delivery services, etc..Even after a contract with a customer is terminated by withdrawal, etc., the personal information may still be used within the scope of the above purposes of use.
      • – Name, sex, address, telephone number, and e-mail address of the customer, and machinery, services, or products the customer uses
      • – Contact information on the customer (name, address, telephone number, e-mail address, etc.)
      • – Name, address, telephone number, etc. for billing, the account number at the designated financial institution, the account name and credit card number, the payment history, etc.
      • – Items classifiable as personal information among the information items recorded in documents provided by the customer for verification of the customer’s identity
      • – Other items classifiable as personal information among the information items the Company handles when customers apply for, use, or make inquiries about the information-providing services or digital content delivery services
    • (ii) The personal information below, that is, information the Company handles when the Company’s customer contact point receives questions, requests, etc. (including proposals for the disclosure of personal information, etc.; hereinafter the same shall apply), may be used not only to the extent necessary to handle the contents of the relevant questions, requests, etc., but also to the extent necessary to improve the quality of information-providing services or digital content delivery services or develop new information-providing services or digital content delivery services based on the contents of the opinions, questions, etc. expressed by customers.- Name, address, telephone number, email-address, etc. of the customer who submits the questions or requests

      – Other items classifiable as personal information among the contents of the questions and requests

    • (iii) The personal information below, that is, information the Company handles when customers participate in questionnaires and other surveys conducted by the Company or apply for prize competitions or members-only programs (hereinafter referred to as “Participation in Questionnaires, etc.”), may be used to the extent necessary to send materials required for questionnaires and other surveys, rewards for questionnaires and other surveys, and gifts for prize competitions, to improve the quality of services, etc., to develop new information-providing services and digital content delivery services, etc., and to introduce the Company’s information-providing services and digital content delivery services, etc.- Name, address, telephone number, e-mail address, age, date of birth, occupation, sex, etc. a customer provides the Company when participating in a questionnaire or another survey

      – Other items classifiable as personal information among the information items a customer provides to the Company when the customer participates in a questionnaire, etc.

    • (iv) Personal information that the Company handles when conducting business consigned by other business entities (sales, brokerage, surveys, etc. for the products or services of other business entities) may be used to the extent necessary for conducting the consigned business. If the Company consigns part of its business, personal information received from the relevant subcontractor may be used to the extent necessary for the business.
    • (v) Pursuant to item 1 of paragraph 4 of Article 23 of the Personal Information Protection Act, personal information that the Company handles may be provided to other business operators to which the Company consigns its business. In addition, personal information may be provided to a third party in accordance with the provisions stipulated in the Company’s contracts and agreements, the Personal Information Protection Act, and other applicable laws and regulations.
  • (2) Basic Concept on Security Control Measures
    The Company will strive to conduct the measures below for the secure control of personal information when it handles the personal information.

    • (i) Technical Protection Measures

      – The Company will strive to prevent unauthorized access to or the divulgence, loss, or damage of personal information by taking appropriate measures to control access to personal information, limit the means of transfer, and protect against unauthorized access from outside, etc.

    • (ii) Organizational Protection Measures

      – The Company will appoint a person responsible for the protection of personal information at each organization handling personal information and make clear the responsibility and authority.

      – In order to securely manage personal information, the Company will establish company regulations, manuals, etc., have its employees who handle personal information in the course of work comply with them, and appropriately manage and supervise the compliance.

      – By implementing proper education and training for its employees who handle personal information in the course of work, the Company will strive to enhance every employee’s awareness in order to ensure that every employee fully recognizes the importance of personal information and handles personal information appropriately at all times.

      – When outsourcing the handling of personal information, the Company will manage and supervise the relevant subcontractor by entering into a confidential agreement, etc. with provisions to ensure that personal information is properly handled.

  • (3) Personal Information from Children
    The Company’s websites, information-providing services, and digital content delivery services for the United States are not intended to be used by children under the age of 13, and the Company does not knowingly collect personal information from anyone under the age of 13, knowingly allow such persons to register, and does not use or disclose such information to third parties. Children under the age of 13 should not use the Company’s websites, information-providing services, or digital content delivery services at any time. If a child under 13 submits personal information to the Company without verification of parental consent and the Company finds that the person submitting the information is a child under 13 or that no parental consent has been confirmed, the Company will delete the information immediately.
  • (4) Procedures for Disclosure, etc.
    The Company has established the following procedures for responding to requests from customers for the disclosure of personal information or disclosure of the purpose of use of personal information (hereinafter referred to as “Disclosures”), or for corrections, additions to, deletions, or suspensions of use of personal information, or suspensions of the provision of personal information to third parties (hereinafter referred to as “Corrections”) (hereinafter such requests are referred to as “Requests for Disclosures and Corrections”).

    • (i) Requests for Disclosures and Corrections
      – e-mail: info@nttsolmare.com
    • (ii) Procedures for Disclosures and Correctionsa. Procedures for Disclosures
      • – The Company will respond to a request for Disclosures from a customer in writing. In this case, the customer shall make the request for Disclosures made by submitting a form designated by the Company in advance.
      • – Even if a customer requests Disclosures, the Company may refrain from disclosing, etc. a part or all of the information in accordance with the provisions of the Personal Information Protection Act. In this case, the Company will inform the customer that the information will not be disclosed, and explain why.
        The Company may refrain from disclosing a part or all of requested personal information to a representative, if such disclosure of personal information would violate the secrecy of communications or could conceivably harm a person’s life, body, property, or other rights or interests.
      • – Customers who want to request Disclosures can do so by contacting the Company’s customer contact point mentioned above.

      b. Procedures for Corrections

      • – Upon receiving a request from a customer for Corrections, the Company will investigate the contents of the request. In this case, the customer shall make the request for Corrections by submitting a form designated by the Company in advance.
      • – If, as a result of the investigation, the Company agrees that the existing contents of personal information is incorrect or that the handling of such personal information is improper, the Company will make the Corrections.
      • – Even if a customer requests Corrections, the Company may refrain from correcting, etc. a part or all of the information in accordance with the provisions of the Personal Information Protection Act. In this case, the Company will inform the customer that the corrections will not be made, and explain why.
      • – Customers who want to request Corrections can do so by contacting the Company’s customer contact point mentioned above.
    • (iii) Verification of Identity of Customer, etc.

      – When a Request for Disclosures or Corrections is made, a written document verifying the identity of the customer (a copy of an official form of identification such as a driver’s license or passport) or verifying that the person who submits the request is in fact a representative of the customer whose personal information is involved the request (a certification) will be required.

    • (iv) Handling charges etc. for Requests for Disclosure, etc.
      • – Handling charge: JPY 1,000 (excluding consumption tax)
      • – Billing method: A bill will be sent for each request.
  • (5) Contact Point for Opinions, etc. regarding the Handling of Personal Information
    The Company’s customer contact point for any questions and requests regarding the handling of personal information in the provision or sale of the Company’s information-providing services and digital content delivery services is as follows.
    – e-mail: info@nttsolmare.com

3. Revisions

The Company may revise a part or all of the content of this privacy policy. If the policy is revised, the
Company will make the revisions public by posting the updated content on this website, etc.

November, 2011

Privacy policy for personal data subject to GDPR

1. Introduction

NTT Solmare Corporation (the “Company”) provides services to customers in many countries. When you use our services, we will acquire, use and store your information. This Privacy Policy established by the Company specifies the purposes of acquiring your personal data by the Company to enable you to understand your rights with respect to such personal data.
Please ensure to read through this Privacy Policy since you need to give your consent and accept the Terms of Use of the relevant service in order to use the Company’s services.

2. Personal Data to be Acquired and Its Intended Use

The Company will acquire the personal data listed below. The personal data to be acquired by the Company will include the information directly provided by you and the information pertaining to your use of the services.
The Company will use such information for performance of contracts or for the purposes specified below, based on your consent.

(1) Information necessary for providing game content
The Company will acquire and use the following information for providing the game content:
a. Information concerning telecommunication devices, and information acquired through cookies and other means
When you use the relevant apps and/or services, we may automatically acquire information on the mobile phone device, tablet, PC and other telecommunication devices you used and also through cookies and other means.
– Information on equipment identification of telecommunication device (device token, register ID, etc.)
– IP address, device name, OS information, browser version, etc. of the telecommunication device
– Information related to crashing of the relevant app (device identifier for crash analysis and crash log data)
– Information related to the progress of the game (progress status, billing status, etc.)

b. Information on login authentication
When you install the relevant app, it will automatically generate your authentication ID. This authentication ID will be the key for storing and updating your game data and is required for your game to progress.

c. Information on passing and linking of the data
In order to allow the relevant service to be used on more than one device, you need to provide us with your Facebook account, or Google ID or Apple game center ID.
Such account and ID information will be used to certify that the owner of those devices is the same person and to synchronize the user data including progress. Meanwhile, the Company will acquire no content or information linked to such account and ID information (e.g., user profile information and information on use of services not related to the relevant service).

d. Information used within the game and exchanged with other users
Your user name used within the game you registered and the communication exchanged with other users in the game will be stored. While the user name you specified is information necessary for progress of the game since it is reflected in the scenario within the game, you can change it at any time.

(2) Information necessary for advertising and marketing purposes
The Company will acquire and use the following information for the purpose of advertising and marketing:
– Advertising identifier of the telecommunication device (IDFA, AAID)
– Information on equipment identification of telecommunication device (device ID)
– Device name, OS information, browser version, etc. of the telecommunication device
– Location information (country, city, town, zip code, etc.)
– In-store search word, advertising information from transition source (e.g., date and time of transition from advertisement to the store)
Out of those, you can reset the advertising identifier yourself by setting your device. For putting restrictions on the advertisements which use IDFA, see Apple Inc.’s website (https://www.apple.com/). For putting restrictions on the advertisements which use AAID, see Google LLC’s website (https://www.google.com/).

(3) Information necessary for responding to inquiries
The Company receives and stores the information you provided to the Company through e-mails (e.g., e-mail address and name).
In addition, when you contact the Company through an inquiry form within the relevant service, the Company will acquire and use the following information in order to respond to your inquiry, demand, complaint and other requests in a proper manner:
– Player ID
– Name of country/region
– Device information (OS and device name)
– History of billing for the relevant service within app (receipt information)
We may also request you to separately provide the screen shot and other materials when the service is used for the purpose of investigation and resolution of your issue.

(4) Participation in surveys
For the following information which is to be handled by the Company as a result of your participation in a survey and other studies conducted by the Company, your entry for a prize competition or enrollment in a membership program (“Participation in Surveys”), the Company will acquire and use it to the extent it is necessary for sending the materials needed for the survey and other studies and a reward for participation in the survey and other studies, sending competition prizes, improving the quality of services, developing new services and introducing the Company’s content distribution and other services.
– Your name, address, phone number, e-mail address, age, date of birth, occupation, gender, etc. provided in participating in a survey and other studies
– Any other items falling under the category of personal information among those provided with your participation in surveys

(5) Entrusted business
For the personal information which is to be handled by the Company in performing the services entrusted by other entities to the Company (distribution, sale on commission, investigation, etc. of products and services of other entities), the Company will acquire and use it to the extent it is necessary for performing the entrusted services.

(6) Provision of your personal data to third parties
The Company may provide a third party with your personal data in accordance with the provisions of the Company’s contractual terms and conditions and applicable laws.

3. Customer’s Choice

Provision of your personal data to the Company will be made upon your consent in principle. If any information necessary for provision of the game content is not provided, the relevant service will not work and the service will not be available for use. In addition, when you put restrictions on advertisements using advertising identifiers, the number of advertisements may not change; however, the relevance of advertisements may become lower than before. In order to withdraw your consent after accepting this Policy, please uninstall the app.

4. Cases Where Parental Consent is Required

The Company will not intentionally collect any personal data from customers under the age of 16 (or other age specified by applicable laws) without obtaining parental consent or unless permitted by the applicable laws. If you are under the age of 16 (or other age specified by applicable laws) and intend to use the Company’s services, you need to check the laws applicable to you to see whether such services may be used without the consent of your parents.

5. Retention Period

The Company will retain your personal data for as long as it is needed for providing you with the relevant service and will erase it promptly when it becomes no longer necessary.

6. Security and Transfer to Other Countries

As needed to provide its services, the Company may, in addition to transferring the customer data to Japan, outsource its handling of the customer data to a subcontractor and other third parties. Such subcontractors include companies having the billing capacity for the relevant service, companies providing customer support services, cloud storage companies, and companies providing advertising/marketing analysis tools, etc. Those third parties include entities outside Japan and it may be possible that they transfer your personal data to a country without personal data protection legislation equivalent to that of the country you live in. In such case, the Company will take any appropriate measures required to protect your personal data in accordance with the requirements of applicable laws and regulations.
The Company complies with the applicable laws and regulations in order to prevent any unauthorized access to or disclosure of your personal data, to maintain the correctness of the personal data, and to dispose of it properly when necessary, and is committed to handling the personal data at a high level of information security. The Company encodes the communication when acquiring or transferring the personal data and puts limitations on the access privileges for the personal data stored, which is handled only by the individuals having a need in performing the duties. In addition, the Company makes a periodic review to ensure that the aforementioned efforts are made effectively and adequately and are made at a proper level.

7. Disclosing Your Personal Data

If you intend to exercise your relevant rights in connection with your personal data (including the rights of access, correction, removal, limitation, data portability, and objection) pursuant to the laws applicable to you, please contact us at info@nttsolmare.com.

8. Amendment to this Privacy Policy

The Company may amend this Privacy Policy on as needed basis in order to respond to amendments to the laws and regulations or in accordance with business needs. When making such amendment, you will be notified of it through the relevant service or communication on our website.

9. Objection

If you believe that the Company’s data processing infringes the applicable laws, you may lodge a complaint with the supervisory authority for data protection in your country pursuant to the laws of your country.

10. Inquiries

Any questions or concerns about this Privacy Policy or handling of customer data should be addressed to:
NTT Solmare Corporation
Sumitomo Building No. 2, 4-7-28 Kitahama Chuo-ku, Osaka 541-0041, Japan
info@nttsolmare.com

Note that, depending on the details of your inquiry, you may be requested to submit additional information so that we can address the issue in a proper manner.

November, 2018