Application Privacy Policy

1. Privacy Policy

ⅰ. Scope

This "DanMachi - MEMORIA FREESE" Application Privacy Policy (this "Policy") provides for the handling of personal data on the "DanMachi - MEMORIA FREESE" game application (the "App") for mobile devices (limited to the mobile devices that can use the iOS provided by Apple, Inc.; the "Mobile Devices") provided by [WFS, Inc.] (the "Company"). With regard to matters that are not provided for in this Policy, please also review the "Basic Policy regarding the Protection of Personal Information."

2. Collection of Personal Data; 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:

<The information you directly provide to Company>

  • Email address
  • Content of communication that takes place on the App
  • Information provided by you when making an inquiry

< The information automatically collected from you>

  • Payment information
  • IP address
  • Usage of the App
  • Identifier for vendor
  • Identification for advertiser

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 the App and other various services, promotions, campaigns, events, etc. operated by the Company or a third party
  • Advertisement placement and their optimization through websites and smartphone or other smart devices applications
  • Rectifying any violations of the Terms of Use
  • Handling inquiries (including identity verification)
  • Providing information to the third parties (including joint users) set forth in "4. Provision to Third Parties; Information Collection Module"

ⅲ. Legal basis

The legal basis for the processing of your personal data is;

  • Your consent.
  • Legitimate interests(to improve and enhance user experience such as answering inquiries from you)

3. Our Policy Regarding Children

The App is not intended for children under 13 years of age, and we do not knowingly collect or solicit personal data from anyone under the age of 13 or knowingly allow such persons to use the App. If you are under 13, please do not send any information about yourself to us, including your name, address, telephone number or e-mail address. No one under the age of 13 may provide any personal data. In the event that we learn that we have collected personal data from a child under the age of 13, we will delete that data. If you believe that we might have received data from or about a child under the age of 13, please contact us at "Customer Information Disclosure and Inquiry Desk" set forth in "5. Personal Information Inquiry Desk" of the "Basic Policy regarding the Protection of Personal Information."

4. Provision to Third Parties; Information Collection Module

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 data to third parties inside and outside the country. In the event that you agree this Policy, you hereby confirm that the Company may disclose the personal data as specified in Section 2i of this Policy to its parent company, GREE, Inc., its affiliate(s), approved subcontractor(s), media or ad agency for the achievement of the purpose of use as specified in Section 2 ii of this Policy.

ⅱ. Information collection module

The App contains the following information collection modules provided by the following third parties for purposes such as providing the features included in the App, displaying advertisements, and analyzing usage. With regard to the purpose of use of the information that will be collected or has been collected through such information collection module, please review the privacy policy that has been provided by each company providing an information collection module:

ⅲ. Disclosure to third parties outside of the country

When you agree to this Policy, you acknowledge that the collected data set forth in this Policy may be transferred outside of your country or region and that there may be cases where the country or region to which the data is transferred does not have laws or regulations imposing protection obligations that are equal to or greater than the laws and regulations regarding personal data and other privacy protection in your country or region. You agree that the Company will disclose the collected data set forth in this Policy to its parent company, GREE, Inc., and its affiliates as well as its approved subcontractors, media, and/or ad agents located in Japan, or the country other than member states of EEA where the approved subcontractor, media or ad agents establish its hub for the purpose of use set forth in this Policy.

5. Method of Notices, Announcements, or Obtaining Consent; Method of User Involvement

ⅰ. Notices and announcements

This Policy is posted and announced on the initial startup screen and the help page on the App as well as on the privacy policy link that is found on the download page for the App in the app store (App Store, etc.). The Company may amend this Policy, and any important changes will be announced on the App or each posting location. The amended Policy will become effective when it is posted on the App or each posting location.

ⅱ. Method for obtaining consent

Please use the App after you have reviewed and agreed to the Terms of Use and this Policy. By using the App (in the case of an amended Policy, by continuing to use the App after the amendment), you will be deemed to have agreed to this Policy. If you do not agree to this Policy (including the amended Policy), you must not use the App.

ⅲ. Suspension of collection and transmission of data

You may stop the collection and transmission of data by deleting (uninstalling) the App from the Mobile Devices.

6. Request for Disclosure, Etc.; Inquiries

ⅰ. Request for access, rectification, erasure, restriction of processing, object to processing, data portability, etc.

You have the right to request from the controller access to and rectification or erasure of personal data or restriction of processing concerning the data subject and to object to processing as well as the right to data portability. If you or your agent makes a request concerning your right listed above, the Company will comply with such request without delay to the extent possible in accordance with laws and regulations. With regard to such requests, please review the Company's "Basic Policy regarding the Protection of Personal Information."

You have the right to lodge a complaint with a supervisory authority which governs your habitual residence with respect to processing of your personal data.

ⅱ. Inquiries

If you wish to make an inquiry, to discuss, or to file a complaint with regard to the handling of personal data in connection with the App, please contact us at "Customer Information Disclosure and Inquiry Desk" set forth in "5. Personal Information Inquiry Desk" of the Basic Policy regarding the Protection of Personal Information.

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.

Post: Data Protection Officer
GREE, Inc.
Roppongi Hills Mori Tower, 6-10-1 Roppongi, Minato-ku,
Tokyo, Japan
dpo@gree.net

ⅳ. Controller of your personal data and its contacts

WFS, Inc.
Roppongi Hills Tower, 6-10-1 Roppongi Minato-ku,
Tokyo, Japan
https://games.gree-support.net/hc/en-us

7. Administration Policy

ⅰ. Amendment of this Privacy Policy

The terms of this Privacy Policy may be revised or amended. Unless otherwise specified by the Company, the revised or amended Privacy Policy will come into effect when it is posted on this website.

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 when the personal data becomes unnecessary to achieve the purpose of use as specified in Section 2 ii..

ⅲ. Others

Please note that if you do not provide Company with the latest and accurate information of yourself, you may not receive appropriate service.

8. Terms for specific Countries

If you reside in any of the places listed below, the relevant terms shall apply;

a. United States (Last Reviewed Date:March 12, 2021)

This Privacy Notice Section 1 ("United States Privacy Notice") supplements and modifies the "Basic Policy regarding the Protection of Personal Information" and the "Application Privacy Policy" of [WFS, Inc.] (the "Company") and applies solely to the user who resides in United States of America ("consumers" or "you"). We adopt this United States Privacy Notice to comply with the California Consumer Privacy Act of 2018 (CCPA), and unless otherwise specified, the terms used in this California Privacy Notice have the meaning defined in the CCPA

1.1 Your personal information the Company collects

  • Email address
  • Payment information
  • IP address
  • Usage of the App
  • Content of communication that takes place on the App
  • Information provided by you when making an inquiry
  • Identifier for vendor
  • Identification for advertiser

1.2 How the Company collects your personal information

  • Directly from you. For example, from actions you take in the App or inquiries you make about the App.
  • Automatically or Indirectly from you. For example, by automatically collecting information or observing your actions when you access the App.

1.3 The purpose to collect and sell your personal information

We may use, sell, or disclose the personal information we collect for one or more of the following purposes:

(1) The purpose to collect your personal information

  • 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 the App and other various services, promotions, campaigns, events, etc. operated by the Company or a third party
  • Advertisement placement and their optimization through websites and smartphone or other smart devices applications
  • Rectifying any violations of the Terms of Use
  • Handling inquiries (including identity verification)
  • Providing information to the third parties (including joint users) set forth in "4. Provision to Third Parties; Information Collection Module"

(2) The purpose to sell your personal information

  • Measuring, studying, and analyzing the usage of the App and the results of implementing various measures
  • Conducting marketing research and surveys
  • Introducing the App and other various services, promotions, campaigns, events, etc. operated by the Company or a third party
  • Advertisement placement and their optimization through websites and smartphone or other smart devices applications

1.4 Sharing or sales of your personal information

(1) The Company may disclose your personal information for a business purpose as follows. We may share your personal information with third parties.

  • Handling inquiries (including identity verification)
  • Rectifying any violations of the Terms of Use
  • Improving the App and fixing bugs
  • Providing the services of the App
  • Measuring, studying, and analyzing the usage of the App and the results of implementing various measures

The third-party service provider to provide the service contemplated under the purpose to use your personal information as follows.

  • Pole To Win Co., Ltd., and its affiliated company located in Singapore.
    (To communicate with you to provide customer support for the App)
  • Pushwoosh Inc., and its subcontractor approved by Company in writing.
    (To use the feature to send you push notification)
  • Microsoft Corporation
    (To examine the download status and crash report for the App)
  • Google LLC
    (To analyze the log of the App, To perform the access analysis for improvements and market research of the App, and To use the feature to send you push notification )

# (2) The Company may sell your personal information subject to your right to opt-out to those sales

  • Adjust GmbH. "Adjust"
    (To identify and analyze the promotional effect of the App)
  • Unity Technologies "Unity Ads"
    (To display video advertisement to users in the App)
  • ironSource Mobile Ltd. "ironsource"
    (To display video advertisement to users in the App)
  • Facebook, Inc. "Facebook Audience Network"
    (To display video advertisement to users in the App)
  • AppLovin Corporation. "AppLovin"
    (To display video advertisement to users in the App)
  • Google LLC "Google Admob"
    (To display video advertisement to users in the App)
  • Tapjoy, Inc. "Tapjoy"
    (To display video advertisement to users in the App)

When users view in-App advertisements, their advertising identifiers and other data are sold to the advertising networks listed above, and users can acquire free-in-App currency.

1.5 Your Rights and Choices

(1) You have the right to request from the controller access to and rectification or erasure of personal information or restriction of processing concerning the data subject and to object to processing as well as the right to data portability. If you or your agent makes a request concerning your right listed above, the Company will comply with such request without delay to the extent possible in accordance with laws and regulations. With regard to such requests, please review the Company's "Basic Policy regarding the Protection of Personal Information."

(2) Personal Information Sales Opt-Out

DO NOT SELL MY PERSONAL INFORMATION

If you are the age of 13-15, you acknowledge and agree that your collected personal information is sold under this United States Privacy Notice by accessing the App.

You may opt-out of future sales at any time after opting-in to personal information sales. You have the right to direct us to not sell your personal information at any time (the "right to opt-out").

IF YOU WANT THE COMPANY NOT TO SELL YOUR PERSONAL INFROMATION, PLEASE FOLLOW THE INSTRUCTION AS FOLLOWS:

  • To opt-out the sale of your personal information to Adjust GmbH "Adjust"

Please follow the instruction as specified in the "Forget Device" page operated by Adjust GmbH. You can access this "Forget Device" page from here

  • To opt-out the sale of your personal information to Unity Technologies "Unity Ads"

Please follow the opt-out instructions in the privacy policy operated by Unity Technologies which can be viewed at the following link.
https://unity3d.com/legal/privacy-policy

  • To opt-out the sale of your personal information to ironSource Mobile Ltd. "ironsource"

Please follow the opt-out instructions in the privacy policy operated by ironSource Mobile Ltd. which can be viewed at the following link.
https://developers.ironsrc.com/ironsource-mobile/unity/ironsource-mobile-privacy-policy/

  • To opt-out the sale of your personal information to Facebook, Inc. "Facebook Audience Network"

Please follow the opt-out instructions in the privacy policy operated by Facebook, Inc. which can be viewed at the following link.
https://www.facebook.com/about/privacy/

  • To opt-out the sale of your personal information to AppLovin Corporation. "AppLovin"

Please follow the opt-out instructions in the privacy policy operated by AppLovin Corporation. which can be viewed at the following link.
https://www.applovin.com/privacy

  • To opt-out the sale of your personal information to Google LLC "Google Admob"

Please follow the opt-out instructions in the privacy policy operated by Google LLC which can be viewed at the following link.
https://policies.google.com/privacy?hl=en

  • To opt-out the sale of your personal information to Tapjoy, Inc. "Tapjoy"

Please follow the opt-out instructions in the privacy policy operated by Tapjoy, Inc. which can be viewed at the following link.
https://www.tapjoy.com/legal/players/privacy-policy/

Please note that in some circumstances, we may not be able to fully comply with your request, such as if it is frivolous or extremely impractical, if it jeopardizes the rights of others, or if it is not required by law, but in those circumstances, Company will still respond to notify you of such a decision. In some cases, we may also need to you to provide us with additional information, which may include personal information, if necessary to verify your identity and the nature of your request.

Established on July 1, 2019
Revised on July 30, 2019
Revised on October 10, 2019
Revised on March 11, 2020
Revised on October 28, 2020
Revised on March 17,2021

©WFS