◆ Privacy Policy ◆

Drecom Co., Ltd. (hereinafter, the “Company,” “we,” “us,” or “our”) understands the significance of the protection of personal information. This privacy policy (the “Privacy Policy”) sets forth how the Company acquires, uses, discloses, transfers, stores, and destroys users’ information and seeks to help users understand our practices with respect to information collected through the mobile application and website, as well as any additional contents and services related thereto provided by the Company (hereinafter collectively referred to as the “Service”).

If you are an individual located in the European Union or European Economic Area, please refer to the GDPR Privacy Policy as it will apply.

If you are a California resident, please refer to the California Annex.

Please visit the Terms of Use of the Service to review the terms that govern your use of the Service.

1. Information to Be Collected by the Company and Method of Collection

1.1 Information About Registered Users

The Company may ask users to provide the following information upon their registration process for the Service:

(1) Username or nickname

(2) E-mail address

(3) Date of birth and other information for verifying the age

(4) IDs and passwords and other information necessary for verifying the identity of the person who accessed the account

(5) User profile (profile image, username for the Service, user ID or nickname, sex, background, link to users’ social media profiles, and other information which users make available in connection with their profile)

(6) Other information which the Company has designated in its mobile application or on its website that it would collect as part of the registration process

(7) Any other information designated by the Company (we will separately notify you of the category of the personal information if such notice is required under applicable laws)

1.2 Device Information

In the event where users use the Service on their devices (including mobile devices), the Company may collect their device identifiers, mobile device identifiers, IP addresses, and other similar device-related information. We may also collect any other device-related information which users provide, such as the names linked to their devices, types of devices, phone numbers, countries, usernames, and e-mail addresses.

1.3 Geolocation Data

In the event where users use the Service on their devices (including mobile devices) and allow the Company to collect their geolocation data, the Company may collect users’ geolocation data.

1.4 Payment Information

In the event where users make in-app purchases or purchase other products through the Service or the licenses to use virtual items from the Company, the Company will collect the payment information required for the payment processing, such as the address and e-mail address. In the event where the third-party payment processors (including but not limited to Apple Inc. and Google LLC) handle the purchases by users, we may collect the billing information and the payment information provided to the payment agencies by the users.

1.5 Information Related to User Activities

Upon users’ use of the Service, the Company may collect and store the information provided directly to us from users as well as the information provided through the third-party service providers that are providing the Service on behalf of us. We may also collect information regarding the state of users’ activities on the Service including their interactions with other users. Most of the information will be collected and stored using the log file, which is a file on the server recording the actions taken on the Service. In the event where users communicate with other users and have participated in certain activities in which information (including texts, user profiles, messages, applications, and other information contents) is shared, the Company may record and store the archives of the information of such communication.

1.6 Information Collected Through Cookies and Other Tracking Technologies

The Company and the service providers acting on behalf of the Company may collect and analyze, using log files and tracking technologies, cookies, IP addresses, device types, mobile device identifiers, types of browsers, browser languages, reference pages and exit pages, platform types, number of clicks, domain names, landing pages, number of page browsed and page browsing order, URL for each page, browsing time for certain pages, date and time of activities on applications or website, or other information. We may also link such information with user ID numbers.

*We use Google Analytics to improve the Service. Google Analytics uses cookies to collect information about the user, which we use to keep the user logged in on our website for a certain period of time and to analyze the user’s visits and website activity. For an explanation of how Google Analytics collects and processes data, please refer to “How Google uses information from sites or apps that use our services.”

1.7 Information Collected Through Interaction with Third Parties

We may collect IDs that users use for third parties as well as the information in which users agreed to disclose to the interacting third parties through their privacy settings with respect to such services.

2. Prohibition on Provision of Personal Information

Please do not provide your personal information to us, if you do not wish for us to process it as described in this Privacy Policy. If you refuse to provide certain personal information, please note that we may not be able to provide our Service to you and that you may not be able to access or use some of the functions of the Service, which may affect your experience.

3. Source of Personal Information

The Company may collect personal information directly from users, automatically from users’ devices, or indirectly from third parties including, without limitation:

・Platforms (e.g., Apple App Store, Google Play, DMM Games, steam)

・Analytics/advertisement partners

・Social media platforms

・Other service providers or third-party business partners

4. Use of Acquired Information

The Company will use the acquired users’ information for the following purposes:

The Company may adjust the retention period of personal information as permitted or required under applicable law, in accordance with Article 10 “Storage and Destruction of Obtained Information” of this Privacy Policy.

The Company may also process personal information other than the above in case the Company separately notifies, in accordance with applicable law.

Provision of personal information of users may be required by law, or to execute contracts, or to perform contractual obligations or other reasons. Should users fail to provide such information, the Company may not be able to provide the Service to them.

5. Sharing or Disclosure of Personal Information to Third Parties

The Company may share or disclose users’ information in the following cases for the purposes set forth hereunder.

(1) Sharing with third-party service providers

We provide users’ information to those third-party service providers who provide various services on our behalf, including, without limitation, payment processing, data analyzing, e-mail transmission, hosting, customer services marketing support, or settlement processing. We will check all third-party service providers to keep the disclosed information confidential and not to use users’ information for any purposes other than for providing the services on our behalf.

(2) Sharing for the interaction with external services

We may provide users’ information to operating companies of the social media services including Facebook and X, Apple Inc., Google LLC, or other external services to interact with them or for the authentication using such external services.

(3) Sharing with third-party advertisers

We may share with third-party advertisers (i) certain technical or network-related information (including IP address and mobile device identifier), (ii) statistical information, and (iii) information relating to the use of the Service. Users agree that the Company or the third-party advertisers may use such information for the analyses of user trend, demographic statistics, and websites analytics as well as for advertisements including behavioral targeting advertisements for the users.

(4) Sharing with SDK providers

Please see Article 6 “External transmission through SDK” below.

(5) Legal requirements

There are occasions where the Company is required to disclose users' personal information in and outside of the country of their residence pursuant to the laws and regulations, legal procedures, or requests from public or governmental organizations.

We may disclose users’ information if we decide that it is reasonably necessary or appropriate for the achievement of national security, law enforcement, or any other public interest.

We may also disclose users’ information if we decide that it is reasonably necessary for the enforcement of our Terms of Use, operation, or the protection of users.

(6) Sale or acquisition

We may transfer to the related parties all or a part of the personal information which we have obtained upon organizational restructuring, merger, or transfer.

(7) Sharing with other users

Part of the Service may include interactions or competitions with other users. When using such services, information such as your username, nickname, profile image, online status, or scores you marked for games may be shown to other users. Please note that any information you post or share may become publicly available, is not subject to this Privacy Policy, and the Company is not responsible for the treatment of such information.

6. External Transmission Through SDK

We use the following software development kits (“SDKs”) provided by the following parties which collect the following information for the following purposes of use.

7. Cross-border Transfer of Personal Information

The personal information of the users may be transferred to the following third-party country, and other countries and regions to which transfer of personal information is required to fulfil the purpose stated in Article 4 “Use of Acquired Information” above.

・Japan

・European Economic Area

・UK

・United States of America

Upon transferring personal information to any of the countries listed above, we will take appropriate protection measures as required by the applicable data protection regulations.

8. Users’ Exercise of Rights

(1) To the extent permitted under applicable law, users may have the following rights or other rights with respect to the personal information that we obtain and use:

(i) Right to access the personal information

(ii) Right to correct the personal information

(iii) Right to delete the personal information

(iv) Right to restrict the processing of the personal information

(v) Right to make objection with respect to the processing of the personal information

(vi) Right to withdraw consent with respect to the processing of the personal information

(2) If you wish to exercise your rights, please make an inquiry using the contact in Article 12 “Inquiries about This Privacy Policy” of this Privacy Policy.

9. For Children

We do not knowingly collect any personally identifiable information from a child.

The term “Children” refers to individuals under the age of 13. In the event where, for some reason, we have obtained any personally identifiable information from a child without a consent from their parents, legal guardian, or representative, we will take appropriate measures to delete such information promptly from our record.

10. Storage and Destruction of Obtained Information

(1) The Company has implemented security measures designed to protect users’ personal information from damages such as loss by accident, fraudulent use or access, and inappropriate disclosure.

(2) The Company will retain users’ personal information only for a period reasonably necessary to achieve the purpose of processing the relevant personal information, or as permitted or required under applicable law. The specific retention period will be determined taking into consideration the purpose of obtaining and processing the personal information, the nature of the personal information, the necessity of retention of the personal information, and applicable law.

(3) The obtained personal information will be destroyed when it is reasonably considered that it is not necessary anymore in light of the normal business operation of the Company or legal processing purposes, etc.

11. Push Notifications and Notices from Service

The Service may transmit push notifications or other notices concerning the use of the Service to users’ devices. Users may disable such notifications by changing the setting of their devices.

12. Inquiries about This Privacy Policy

If you have any questions or inquiries with respect to this Privacy Policy, please contact below. If there is any contact route designated in the relevant Service, such route will be prioritized.

Privacy Policy contact point:

Drecom Co., Ltd.

Address: 2-1-1 Osaki, Shinagawa-ku, Tokyo, Japan

E-mail address: privacy@drecom.co.jp

Contact us: Click here

13. Changes to This Privacy Policy

The Company may update this Privacy Policy from time to time. Any important changes will be posted in the Service along with the latest Privacy Policy.

Established on March 25, 2021

Updated on June 25, 2021

Updated on September 29, 2022

Updated on July 1, 2023

Updated on February 29, 2024