TopPrivacy Policy
(*Privacy Policy for users in the EEA, UK, Australia, Brazil, Mexico and Thailand is available here.)
Updated: February 28, 2024
In this Privacy Policy, “DeNA”, “we”, “us”, or “our” means DeNA Co., Ltd. and its subsidiaries.
Your privacy is important to DeNA. We designed our Privacy Policy to cover how we collect and use your information in connection with use of or access to our software and media dedicated to that software (“Services”). By using our Services, you agree to our collection and use of your information, including your personal information, as described in this Privacy Policy. This Privacy Policy should be read together with our End-User License Agreement (“EULA”).
So please take a moment to learn the five W's, the How, and other important matters about the information we collect and how we use it. If you have any questions, please contact us.
Please note that the short summaries set forth in the headers below are for clarification purposes only, and are detailed in the subsequent sections of this Privacy Policy.
Both non-personal information and personal information may be collected and used by us.
The primary objective for our collection and use is to deliver and improve our Services.
When you provide information to us, use the Services, or register or connect with a third-party account system (“Account System”) in connection with use of our Services.
By providing information to us directly, using the Services, or registering or connecting with an Account System in connection with use of our Services.
We may also use cookies and other electronic means to collect your personal information, but options are available to remove/disable certain cookies by the settings on your browser.
Services-related promotions may also be used by us; if you opt in, or as permitted by law, these services may include the sending of commercial electronic messages.
We may disclose your information with persons who help us provide the Services, but only as necessary, and only to persons who are bound contractually to keep the information confidential, use it only to assist us in providing the Services, and protect using appropriate security safeguards.
Except only in special circumstances, we never transfer your personal information to advertisers or marketers for their own use without your separate consent.
We do not knowingly collect personal information from minors in your country or state.
In line with this Privacy Policy, your information may be processed in Japan and other countries, as necessary, where it may be subject to laws different than your home country.
We may change this Privacy Policy, so please check for any updates.
You have certain options with respect to how your personal information may be used or disclosed.
Measures are taken to safeguard information received from you, and we keep your personal information only as long as necessary.
Certain provisions of this Privacy Policy are for California residents; if you are a California resident, please see additional information below.
In the course of using our Services, you may provide us, directly and indirectly, with both personal and non-personal information. Personal information includes any factual or subjective information that can be used, on its own or in combination with other information, to identify you as an individual, and might include your name, phone number, pictorial representation, email address, postal address, opinions, comments, age, etc. Non-personal information is information that does not permit direct association with you, including personal information which has been aggregated with other users' information such that it can no longer be attributed to any individual. Certain non-personal information would be considered a part of your personal information if it were combined with other identifiers (e.g., combining your zip or postal code with your street address) in a way that enables you to be identified. But the same pieces of information are considered non-personal information if they are taken alone or combined only with other non-personal information (e.g., your viewing preferences), provided the information cannot otherwise be linked or attributed back to you as an identifiable individual.
Our primary objective in collecting your information is to provide you with a superior and personally relevant user experience. To achieve this, your information may be used as follows or by requesting explicit consent where required by law:
To help us develop, deliver (in accordance with the EULA), and improve our Services, including the following aspects of our Services:
messaging and other communication to and with users
the creation, updating, accessing, and maintaining of lists of contacts
transactions for and use of virtual currency and virtual items
communication and user-interactive features
for purposes of tracking achievements on application platforms
authentication purposes
recommending Services-related products or services of interest directly to you
for market research purposes that support our efforts to deliver a more valuable service to our community of users
to contact you with announcements, newsletters, and promotional materials related to our Services or to offer you opportunities to participate in surveys, contests, or sweepstakes (any of these a “Promotion”) via our Services.
to provide end-user support.
to prevent and take measures against fraud, illegal activities, infringement of our rights or interests, or breaches of our EULA and this Privacy Policy.
to send important notices, such as changes to our EULA, this Privacy Policy, or other Services-specific policies. Because this information is important to your interactions with us, you may not opt out of receiving these communications.
to audit and analyze data for technical administration, to improve our Services, and for end-user communications.
Your information is collected by us when you directly interact with our Services, including by filling out your user profile in our application, and otherwise through use of our Services via the device you use to access or use our Services (“Device”).
Your information may also be made available to us when you register with any Account System for use of our Services and/or permit any Account System to share any of your information with us in connection with your use of our Services, including account ID, country, region, language and username, and when any changes are made to that information. By accepting an Account System's applicable terms, you agree for the Account System to make such information available to us on those terms.
When you use our Services, we collect information related to your Device as described in “The How” section below.
If you choose to participate in a Promotion, we may request that you provide us with personal information such as your email address or postal address in order to administer your participation in the Promotion.
As already mentioned, we may collect information from you when you directly interact with our Services and otherwise indirectly through your access to or use of our Services. You may have certain options to control the use of these technologies – see Your Choices.
Direct interaction may include such actions as creating a username, or sharing of your contents with other users in our Services. We may but are not required, to collect and store the information referred to in this paragraph.
We may also collect your information from third parties who provide it to us, including other users of our Services and, as noted above, any Account System you engage with related to our Services.
As is standard practice, we do use “cookies” in connection with the Services. A cookie is a small string of text placed on your Device. In addition to strictly necessary cookies that enable us to provide our Services (such as those that provide your Account System log-in status when that account ID is linked to functionality on the Services), we may use both performance-gauging and functionality-gauging cookies. Performance-gauging cookies reveal how you use the Services, for instance, which content is the most popular, how much time users are spending there, and what advertising is relevant to you, which helps us provide an optimized experience (we may engage third parties to carry out this analysis, and they may set their own “third party” cookies--see “The Who” for more). Functionality-gauging cookies enables us to remember certain choices you make in interacting with the Services, for instance, any geographic location, language, or fonts you choose, which helps us tailor the Services to your preferences. Neither performance-gauging cookies nor functionality-gauging cookies collect information in any way that personally identifies you.
Except for cookies strictly necessary to enable us to provide our Services, you have the option to disable cookies stored on your browser by changing the options in your browser to stop accepting cookies or to prompt you before accepting a cookie from the content you visit. If you do not accept cookies, you may not be able to view or use parts of our Services due to limited functionality. Some cookies we use may be stored using a web-browsing component other than a browser application--these cannot be disabled on your Device, but the information collected does not personally identify you, and does not permit tracking between Services.
Some of our Services, including messaging, may use “click-through URLs” linked to other content on our Services. We track this click-through data in aggregate to help us determine interest in topics, Services usability, and other measures of user engagement.
In using our Services, our servers record information sent from your Device such as device name, mobile carrier, operating system, application version, personal settings (such as language and advertising tracking settings), Internet Protocol (“IP”) address, , cookie identifier, network type, time zone, log information (such as site access history and information about how you interact with application) and usage information (such as user ID, activities information (including payment amount), and crash log data).
UNLESS OTHERWISE SPECIFIED HEREIN, BY ACCESSING OUR SERVICES, YOU ARE CONSENTING TO THE USE OF COOKIES AND THE OTHER ABOVE TECHNOLOGIES UNDER THE TERMS OF THIS PRIVACY POLICY.
We will collect and use your information as explained in this Privacy Policy. As a user of our Services, we offer functions that allow you to use and create your own profile, and share your contents with other users.
As mentioned in “The Why”, social interaction may be a function that is offered as a part of our Services. You understand and agree that your contents may be viewable in the Services by other users if they enter your username, for purposes of searching your contents in the Services.
You agree that we may disclose your information as follows:
Disclosure of your information may also occur where we engage or employ service providers, vendors, or other third parties to help us provide our Services (each a “Service Provider”) (e.g., improvement of our Services' features, promotion and marketing, administration, analytics, customer service, cloud storage, hosting, and other related services), to provide the Services on our behalf, or to assist us in analyzing how our Services are being used. Our Service Providers may have access to your personal information only to perform these tasks on our behalf, and they are directed not to disclose or use your personal information for any other purpose, and to protect your information to a level reasonably comparable with the safeguards we use.
In some instances, we may disclose information about you where legally permitted, including to law enforcement officials or private parties if we believe it is necessary or appropriate to respond to claims and legal process (including subpoenas), to protect the property and rights of DeNA or a third party, to protect the safety of the public or any person, or to prevent or stop activity we may consider to be, or to pose a risk of being, illegal, unethical, or legally actionable activity.
In other cases, for example, in connection with a merger, acquisition, reorganization, or sale of assets, or in the event of bankruptcy, we may sell or transfer some or all of our assets. In connection with such a transaction, we may transfer all of the information about you in our records, including personal information, to any successor entity.
We do not knowingly collect personal information from, or store personal information of minors in your country or state. We will upon notice or discovery take all reasonable efforts to erase or destroy any such personal information that may have been collected or stored by us without our knowledge or consent.
You understand and agree that we may transfer your information to and process it in Japan and other countries outside of your country of residence. Such transfer could subject the user's personal information to foreign laws, which may provide different levels of protection than those in your home country.
We reserve the right to change, amend or modify this Privacy Policy at any time. If we change this Privacy Policy in a material way, we will give notice of that in the Services, on our website, and/or by email to any email address we may have for you at that time. Your use of our Services after we have changed the Privacy Policy will indicate your consent to the updated Privacy Policy.
Unless you indicated otherwise at installation or chose not to receive push and local notifications, we may send push and local notifications to your Device concerning updates, events, and special offers for our Service and other applications of the Services installed on your Device. Please note that you have the option of deactivating push and/or local notifications by changing the settings of the application or of your Device.
We take your privacy very seriously and employ reasonable administrative, physical, and electronic measures to safeguard information received from you and held by us against identity theft and unauthorized access or alteration. In addition, we will take reasonable steps to assure that third parties to whom we transfer any data will provide sufficient protection of your personal information. We do not and will not, at any time, request your credit card information, login password, or any national identification numbers in a non-secure or unsolicited communication (e.g., via e-mail, telephone, or mobile device). We will not keep your personal information any longer than needed for the purpose it was collected or than is necessary for legal or legitimate business purposes.
We will make any legally required disclosures of any breach of the security, confidentiality, or integrity of your unencrypted electronically stored “personal data” or “personal information” (as defined in applicable statutes on security breach notification) to you via email or conspicuous posting on our website in the most expedient time possible and without unreasonable delay, consistent with (i) the legitimate needs of law enforcement; or (ii) any measures necessary to determine the scope of the breach and restore the reasonable integrity of the data system.
If you have any concerns with the way we collect and handle your personal information, or would like to correct or request that we delete such personal information held by us, please contact us. We will use commercially reasonable efforts to honor your request; please note, though, that at a minimum we may retain an archived copy of your records as required by law or to send necessary communications to you under this Privacy Policy. You understand that deletion of your personal information may result in you not being able to view or use portions of our Services which depend on such information.
For a Promotion you have opted into, you have the option to opt out at any time from participation in such Promotion and the receipt of any related communications by following unsubscribe instructions provided in the relevant communications, or by selecting not to receive communications from us where the relevant media service offers that option.
Our Services may contain links to other websites and online services or offers from third parties. For example, our Services may include offers from third-party advertisers or the ability to engage in transactions with such entities. If you choose to participate in offer-linked information requests or “click on” an advertisement or another third-party link, you may be directed to that third party's website or service and/or be prompted to provide personal information in connection with such activity.
The fact that we allow linking to a third-party website or service (including Account System, and optional mobile application recovery services) is not an endorsement or representation of our affiliation with that third party, nor is it an endorsement of such third party's privacy or information security policies or practices or their compliance with any laws. We do not exercise control over third-party websites or services, and this Privacy Policy does not apply to information you provide or collected by them. These other websites or services may place their own cookies or other tracking devices on your computer or mobile device, or collect data or solicit personal information from you. Other websites and services follow different rules regarding the use or disclosure of the personal information you submit to them. We encourage you to read the privacy policies or statements of the other websites and services you use and the terms of the offers in which you participate. You agree that we are not responsible for, nor will we be liable to you or any third party for, your interaction with such third parties or the information requests initiated by such third parties or the subsequent use, treatment, or dissemination of the information you provide to them.
To the extent that any of our mobile applications of the Services collect personally identifiable information, that is done only as strictly necessary to enable us to provide those Services (see The How, above), and this cannot be disabled by “do not track” or other mechanisms available via your mobile Device's browser.
California residents may have additional rights and choices related to identifying information and other types of personal information.
This section covers how we collect and use your information in connection with the use of the mobile application software and media dedicated to that software and applies solely to California residents.
If you are a California resident, California law requires us to provide you with some additional information regarding how we collect, use, and disclose your “personal information” as defined in the California Consumer Privacy Act as replaced by the California Privacy Rights Act(“CCPA”).
Throughout our Privacy Policy, including “The What” and “The When” sections, we discuss in detail the specific pieces of personal information we collect from and about users.
Under the CCPA, we are also required to provide you with the “categories” of personal information we collect. The categories we collect are:
Contact identifiers such as your username, and user ID, and contact information (for Promotion purposes) such as names, addresses, phone numbers, and email addresses;
Characteristics or Demographics, such as your date of birth and gender;
Commercial or transactions information, such as records of products or services you purchased, obtained, or considered;
Internet or other network or device activity, such as browsing history or Services usage;
Non-precise location data, such as location derived from an IP address or data that indicates a city or postal code level;
Inferences drawn from any of the above information identified in this section;
Payment information including your payment instrument number (such as a credit or debit card number), expiration date, and security code as necessary to process your payments;
User-generated content, including content within any messages you send to us (such as feedback, questions, or survey responses) or publicly post on the Service;
Precise location data, such as latitude/longitude, with your consent; and
Audio information, such as customer service call recordings if you do not opt out.
We disclose all of above categories of personal information to:
Our affiliates and subsidiaries;
Our service providers, such as marketing and advertising services, providers of payment and accounting services, transactional support providers, and providers of technical services (e.g., data storage, security, and customer relationship management databases); and
Other parties where required by law or to protect our rights.
For the categories of sources from which personal information is collected, see “The When” and “The How” sections, above.
For additional information regarding the categories of third parties to whom information is disclosed, see “The Who” section above.
We and our service providers may use the categories of personal information we collect from and about you for the following business purposes and commercial purposes (as those terms are defined in applicable law):
Our or our service provider's operational purposes;
Auditing consumer interactions on our site;
Detecting, protecting against, and prosecuting security incidents and fraudulent or illegal activity;
Bug detection and error reporting;
Providing the Services (e.g., account servicing and maintenance, customer service, advertising and marketing, analytics, and communication about the Services);
Improving our existing Services and developing new services (e.g., by conducting research to develop new products or features);
Other uses that advance our commercial or economic interests;
Other uses about which we notify you.
Examples of these types of uses are discussed in “The How” section of this Privacy Policy. We may also use the categories of personal information for compliance with applicable laws and regulations, and we may combine the information we collect (“aggregate”) or remove pieces of information (“de-identify”) to limit or prevent identification of any particular user or device.
We retain the categories of personal information we collect from and about you in accordance with our internal retention policies no longer than the period reasonably necessary for each purpose described in “The Why” section.
We do not sell or share information that directly identifies you such as your name and email address. We disclose certain information as set forth in “The Who” section and allow third parties to collect certain information about your activity, for example through cookies, as explained in “The How” section. You can control these cookies through browser settings and other controls. We do not believe these activities are a sale or a share of personal information as such terms are defined under the CCPA. Please note that we also do not knowingly sell the personal information of minors under 16 years of age without legally-required affirmative authorization.
If you are a California resident, you may have certain rights. California law may permit you to request that we:
Allow you to exercise your right to know what personal information we have collected about you, including the categories of personal information, the categories of sources from which personal information is collected, the business or commercial purposes for collecting, selling, or sharing personal information, the categories of third parties to whom we disclose personal information, and the specific pieces of personal information we have collected about you.
Delete certain information we have about you.
Correct inaccurate information we have about you.
You have the right to not be discriminated against (as provided for in applicable law) for exercising certain of your rights. Certain information may be exempt from such requests under applicable law. For example, we need certain types of information so that we can provide the Services to you and for compliance with applicable law. If you ask us to delete certain information, you may no longer be able to access or use the Services.
If you would like to exercise any of these rights, please contact Customer Support at support@programmingzemi.com. If you have an account with us, we may require you to use the account to submit the request. We will confirm receipt of your request within 10 business days and respond to your requests within 45 days.
You can also designate an authorized agent to make a request on your behalf. To do so, , except with regards to your rights to opt-out of the sale or sharing of your personal information, you must provide us with written authorization or a power of attorney, signed by you, for the agent to act on your behalf. In all cases in which you (or your authorized agent) make a request to exercise your CCPA rights, you will be required to verify your identity directly with us, which may include, verifying your identity through contacting us through the Services via your device and/or verifying certain historical information regarding your use of the Service. If you are unable to verify your identity, we will be unable to respond your requests.
California's Shine the Light law permits those of our customers who are California residents the right to request (i) a list of the categories of personal information disclosed by us to third parties during the immediately preceding calendar year for those third parties' own direct marketing purposes; and (ii) a list of the categories of third parties to whom we disclosed such information. To make such a request, please contact us and specify that you are making a “California Shine the Light Request.” We may require additional information from you to allow us to verify your identity and are only required to respond to requests once during any calendar year.
If you are a California resident under 18 years old and registered to use the Service, under California's Online Eraser Law, you can ask us to remove any content or information you have publicly posted on the Service. To make a request, please write to us at the email address set out in the Contact Us section above with “California Under 18 Online Eraser Request” in the subject line, and tell us what you want removed. We will make reasonable good faith efforts to remove the post from prospective public view, although we cannot ensure the complete or comprehensive removal of the content and may retain the content as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements.
California law permits those of our customers who are California residents the right to request certain information regarding our disclosure of personal information to third parties for their direct marketing purposes. To make such a request, please contact us.
If you have any questions, inquires, requests, or complaints concerning this Privacy Policy or our information collection practices, please contact us at support@programmingzemi.com addressed to “App Specialist” or by post:
Attn: App Specialist, DeNA Customer Support Center, Shibuya Scramble Square, 2-24-12 Shibuya, Shibuya-ku, Tokyo 150-6140 JAPAN.
Effective Date: February 28, 2024
(for users in the EEA, UK, Australia, Brazil, Mexico and Thailand)
In this Privacy Policy, “DeNA”, “we”, “us”, or “our” means DeNA Co., Ltd. and its subsidiaries.
Your privacy is important to DeNA. We designed our Privacy Policy to cover how we collect and use your information in connection with use of or access to our software, and media dedicated to that software (“Services”). By using our Services, you agree to our collection and use of your information, including your personal information, as described in this Privacy Policy. This Privacy Policy should be read together with our End-User License Agreement (“EULA”).
So please take a moment to learn the five W's, the How, and other important matters about the information we collect and the manner we use it. If you have any questions, please contact us.
Please note that the short summaries set forth in the headers below are for clarification purposes only, and are detailed in the subsequent sections of this Privacy Policy.
We may collect and use both non-personal information and personal information may be collected and used by us.
The types of data we collect from you and which data is used for what purpose.
The primary objective for our collection and use is to deliver and improve our Services.
When you provide information to us, use the Services, or register or connect with a third-party account system (“Account System”) in connection with use of our Services.
By providing information to us directly, using the Services, or registering or connecting with an Account System in connection with use of our Services.
We may also use cookies and other electronic means to collect your personal information, but options are available to remove/disable certain cookies by the settings on your browser.
We may also use services-related promotions may also be used by us; if you opt in, or as permitted by law, these services may include the sending of commercial electronic messages.
We may share your information with persons who help us provide the Services, but only as necessary, and only to persons who are bound contractually to keep the information confidential, use it only to assist us in providing the Services, and protect using appropriate security safeguards.
Except only in special circumstances, we never transfer your personal information to advertisers or marketers for their own use without your separate consent.
We do not knowingly collect personal information from minors in your country or state.
In line with this Privacy Policy, your information may be processed in Japan and other countries, as necessary, where it may be subject to laws different than your home country.
We may change this Privacy Policy, so please check for any updates.
Under current applicable laws and regulations, you can exercise the certain rights associated with your personal data
Measures are taken to safeguard information received from you, and we keep your personal information only as long as necessary.
In the course of using our Services, you may provide us, directly and indirectly, with both personal and non-personal information. Personal information includes any factual or subjective information that can be used, on its own or in combination with other information, to identify you as an individual, and might include your name, phone number, pictorial representation, email address, postal address, opinions, comments, age, etc. Non-personal information is information that does not permit direct association with you, including personal information that has been aggregated with other users' information such that it can no longer be attributed to any individual. Certain non-personal information would be considered a part of your personal information if it were combined with other identifiers (e.g., combining your zip or postal code with your street address) in a way that enables you to be identified. But the same pieces of information is considered non-personal information if taken alone or combined only with other non-personal information (e.g., your viewing preferences), provided the information cannot otherwise be linked or attributed back to you as an identifiable individual.
Some data is necessary for enabling us to provide the registration to and usage of our Services. This includes the data below.
| Type | Categories of personal data | Purpose of use | Legal grounds relied upon |
|---|---|---|---|
| Information you voluntarily choose to provide | Data to create your account (such as language and username) | To help us develop, deliver, and improve our Services, including the following aspects of our Services:
|
Contractual necessity, namely this data is used by us to provide (as well as operate, customize and support) the Services that you have requested, and we have agreed to provide to you. |
| Your messages to the Services | |||
| Information collected automatically when you use our Services | Usage information (such as user ID, activities information (including payment amount) and crash log data) | ||
| Online identifiers (such as IP address) | |||
| Log information (such as site access history) | |||
| Cookie identifier | |||
| Hardware information (such as application version, operating system, mobile carrier, device name, network type, personal settings (such as language settings) and time zone) | |||
| Information you voluntarily choose to provide | Data to create your account (such as language and username) | To prevent and take measures against fraud, illegal activities, infringement of our rights or interests, or breaches of our EULA and this Privacy Policy, and to preserve and share information where we seek legal advice, seek to protect ourselves in the context of litigation and other disputes and respond to legal requests and law enforcement agencies, regulators or other bodies (whether we are compelled by applicable law or if we believe in good faith that it is required by law in the relevant jurisdiction). This includes matters pertaining to violations of our EULA and other policies. | Legitimate interests, namely:
|
| Your messages to the Services | |||
| Information collected automatically when you use our Services | Usage information (such as user ID, activities information (including payment amount) and crash log data) | ||
| Online identifiers (such as IP address) | |||
| Log information (such as site access history) | |||
| Cookie identifier | |||
| Hardware information (such as application version, operating system, mobile carrier, device name, network type, and time zone) | |||
| Information you voluntarily choose to provide | Data to create your account (such as date of birth, country, region, language and username) | To audit and analyze data for technical administration, to improve our Services, and for end-user communications. | Legitimate interests, namely:
|
| Your messages to the Services | |||
| Information collected automatically when you use our Services | Usage information (such as user ID, activities information (including payment amount) and crash log data) | ||
| Online identifiers (such as IP address) | |||
| Log information (such as site access history and information about how you interact with the Services) | |||
| Cookie identifier | |||
| Hardware information (such as application version, operating system, mobile carrier, device name, network type, personal settings (such as language settings) and time zone) |
In addition to the above data, we would also like to use the below data for general advertisement purposes and to inform you of our future offers and similar products.
| Type | Categories of personal data | Purpose of use | Legal grounds relied upon |
|---|---|---|---|
| Information you voluntarily choose to provide | Data to create your account (such as date of birth, country, region and language) | For market research purposes that support our efforts to deliver a more valuable service to our community of users, including using your information to contact you with announcements, newsletters, and promotional materials related to our Services or to offer you opportunities to participate in surveys, contests, or sweepstakes (collectively “Promotions”) via our Services. | We will obtain your consent before using your data for these purposes. If you provide consent, you will be entitled to withdraw consent at any time in accordance with the process set out in the “Withdrawal of Consent” section below. |
| Information collected automatically when you use our Services | Usage information (such as user ID, activities information (including payment amount)) | ||
| Online identifiers (such as IP address) | |||
| Log information (such as information about how you interact with Services) |
Direct interaction and use of our Services
We will collect your information when you directly interact with our Services, including by filling out your user profile in our application, and otherwise through use of our Services via the device you use to access or use our Services (“Device”).
Your information may also be made available to us when you register with any Account System for use of our Services and/or permit any Account System to share any of your information with us in connection with your use of our Services, including account ID, country, region, language and username, and when any changes are made to that information. By accepting an Account System's applicable terms, you agree for the Account System to make such information available to us on those terms. When you use our Services, we collect information related to your Device as described in “The How” section below.
If you choose to participate in a Promotion, we may request that you provide us with personal information such as your email address or postal address in order to administer your participation in the Promotion.
We will not keep your personal information any longer than needed for the purpose it was collected or than is necessary for legal or legitimate business purposes.
As already mentioned, we may collect information from you when you directly interact with our Services and otherwise indirectly through your access to or use of our Services. You may have certain options to control the use of these technologies – see “Other Important Matters”.
Direct interaction may include such actions as creating a username, or creating a contacts' list. It may also include the sharing your contests with other users in our Services. We may but are not required, to collect and store the information referred to in this paragraph.
We may also collect your information from third parties who provide it to us, including other users of our Services and, as noted above, any Account System you engage with related to our Services.
As is standard practice, we do use “cookies” in connection with the Services. A cookie is a small string of text placed on your Device. In addition to strictly necessary cookies that enable us to provide our Services (such as those that provide your Account System log-in status when that account ID is linked to functionality on the Services), we may use both performance-gauging and functionality-gauging cookies. Performance-gauging cookies reveal how you use the Services, for instance, which content is the most popular, how much time users are spending there, and what advertising is relevant to you, which helps us provide an optimized experience (we may engage third parties to carry out this analysis, and they may set their own “third party” cookies--see “The Who” for more). Functionality-gauging cookies enables us to remember certain choices you make in interacting with the Services, for instance, any geographic location, language, or fonts you choose, which helps us tailor the Services to your preferences. Neither performance-gauging cookies nor functionality-gauging cookies collect information in any way that personally identifies you.
Except for cookies strictly necessary to enable us to provide our Services, you have the option to disable cookies stored on your browser by changing the options in your browser to stop accepting cookies or to prompt you before accepting a cookie from the content you visit. If you do not accept cookies, you may not be able to view or use parts of our Services due to limited functionality. Some cookies we use may be stored using a web-browsing component other than a browser application--these cannot be disabled on your Device, but the information collected does not personally identify you, and does not permit tracking between Services.
Some of our Services, including messaging, may use “click-through URLs” linked to other content on our Services. We track this click-through data in aggregate to help us determine interest in topics, Services usability, and other measures of user engagement.
In using our Services, our servers record information sent from your Device such as device name, mobile carrier, operating system, application version, personal settings (such as language and advertising tracking settings), Internet Protocol (“IP”) address, , cookie identifier, network type, time zone, log information (such as site access history and information about how you interact with our Services) and usage information (such as user ID, activities information (including payment amount), and crash log data).
UNLESS OTHERWISE SPECIFIED HEREIN, BY ACCESSING OUR SERVICES, YOU ARE CONSENTING TO THE USE OF COOKIES AND THE OTHER ABOVE TECHNOLOGIES UNDER THE TERMS OF THIS PRIVACY POLICY.
We will collect and use your information as explained in this Privacy Policy. As a user of our Services, we offer functions that allow you to use and create your own profile, and share your contents with other users.
As mentioned in “The Why”, social interaction may be a function that is offered as a part of our Services. You understand and agree that your contents may be viewable in the Services by other users if they enter your username, for purposes of searching your contents in the Services.
To the extent you have agreed in the consent form with regards to section “The What and the Why” above, we may share your information as follows:
Sharing of your information may also occur where we engage or employ service providers, vendors, or other third parties to help us provide our Services (each a “Service Provider”) (e.g., improvement of our Services' features, promotion and marketing, administration, analytics, customer service, cloud storage, hosting, and other related services), to provide the Services on our behalf, or to assist us in analyzing how our Services are being used. Our Service Providers may have access to your personal information only to perform these tasks on our behalf, and they are obligated not to disclose or use your personal information for any other purpose, and to protect your information to a level reasonably comparable with the safeguards we use.
In some instances, we may disclose information about you where legally permitted, including, to law enforcement officials or private parties if we believe it is necessary or appropriate to respond to claims and legal process (including subpoenas), to protect the property and rights of DeNA or a third party, to protect the safety of the public or any person, or to prevent or stop activity we may consider to be, or to pose a risk of being, illegal, unethical, or legally actionable activity.
In other cases, for example, in connection with a merger, acquisition, reorganization, or sale of assets, or in the event of bankruptcy, we may sell or transfer some or all of our assets. In connection with such a transaction, we may transfer all of the information about you in our records, including personal information, to any successor entity.
We do not knowingly collect personal information from, or store personal information of minors in your country or state. Upon notice or discovery, we will take all reasonable efforts to erase or destroy any such personal information that may have been collected or stored by us without our knowledge or consent.
You understand and agree that we may transfer your information to and process it in Japan and other countries outside of your country of residence.
We may transfer your information to and process it in Japan and other countries outside your country of residence, including in countries whose data protection laws may be of a lower standard than those in your country
In order to ensure an adequate and consistent level of protection of your personal data, we do not transfer personal data to recipients outside the EU/EEA or UK unless:
―the jurisdiction in which the recipient is located is deemed to provide an adequate level of data protection;
―there are appropriate safeguards in place (e.g. binding corporate rules; contractual arrangements with the recipient of the personal data, using, for example, the standard contractual clauses approved by the European Commission or the UK Information Commissioner's Office, adherence to a code of conduct or certification mechanism together with obtaining binding and enforceable commitments from the recipient) or
―a derogation or exemption applies (e.g. where an individual has explicitly consented to the proposed transfer after having been provided with all necessary information about the risks associated with the transfer).
We reserve the right to change, amend or modify this Privacy Policy at any time. If we change this Privacy Policy in a material way, we will give notice of that in the Services, on our website, and/or by email to any email address we may have for you at that time. Your use of our Services after we have changed the Privacy Policy will apply the Privacy Policy in effect at the time your information is collected.
We have designated our representatives in accordance with the applicable data protection law in EU/EEA or UK as follows;
Representative in the EU/EEA:
PLANIT // LEGAL
Attn: DeNA Co. EU Representative
Address: Jungfernstieg 1, 20095 Hamburg, Germany
Email address: dena_eu_representative@planit.legal
Representative in UK:
Simmons & Simmons LLP
Address: 1 Ropemakers St., London, EC2Y 9SS
Phone:+44 20 7628 2020
Email address: DeNA-UK-representative@simmons-simmons.com
For the exercise of any of your rights mentioned below, please contact us by email at support@programmingzemi.com or by post Attn: DeNA Customer Support Center, Shibuya Scramble Square, 2-24-12 Shibuya, Shibuya-ku, Tokyo 150-6140.
Please note that we may need to verify your identity before we can act on your request and, because the exercise of these rights is subject to certain legal conditions and limitations, we may have to decline your request if those conditions are not fulfilled or if legal limitations apply. We may also reject requests that are unreasonably repetitive, require disproportionate technical effort (for example, developing a new system or fundamentally changing an existing practice), or create a risk on the privacy of others. Where we cannot fulfil your rights due to an exception, we will provide an explanation.
In accordance with applicable data protection law you are entitled to exercise the following rights:
You can withdraw your consent for the collection, usage and storage of your information and data free of charge and at any time by giving us reasonable notice. Your withdrawal can be sent via mail to support@programmingzemi.com or by post Attn: DeNA Customer Support Center, Shibuya Scramble Square, 2-24-12 Shibuya, Shibuya-ku, Tokyo 150-6140 JAPAN.
Upon receiving your request, we will inform you of the likely consequences of the withdrawal of your consent, and will cease to process your information therefrom, unless otherwise permitted or required by applicable laws and regulations. Please note that if you withdraw your consent to any or all usage of your data that enables us to provide our Services, depending on the nature of your request, we may not be able to provide to you our Services anymore.
You have the right to request anytime information about the data stored by us concerning you, their source and their recipients as well as the purpose of the data processing. You further have the right of correction, and the right of deletion of the data stored with us anytime. In this respect, it is important that the personal data we hold about you is accurate and current: please keep us informed if your personal data changes during the period for which we hold your data.
You also have the right to erasure of your personal data.
You have the right to object at any time to the processing of personal data concerning yourself which are necessary for the purposes of the legitimate interests pursued by us. We will no longer process the personal data unless there are legitimate grounds for the processing that override the interests, rights and freedoms of you or for the establishment, exercise or defense of legal claims.
You have the right to obtain restriction of procession when:
you contest the accuracy of the personal data, for a period enabling us to verify the accuracy of the personal data;
the processing is unlawful and you oppose the erasure of the personal data and request the restriction of their use instead;
we no longer need the personal data for the purposes of the processing, but they are required by you for the establishment, exercise or defense of legal claims;
you have objected to processing your data pending the verification whether the legitimate grounds of us override those of yours.
You have the right to receive the personal data concerning yourself, which you have provided to us, in a structured, commonly used and machine-readable format and have the right to transmit those data to another controller without hindrance from us, where:
the processing is based on consent;
the processing is carried out by automated means
In exercising your right to data portability, you have the right to have the personal data transmitted directly from us to another controller, where technically feasible. The exercise of the right to data portability is without prejudice to the right to erasure.
Without prejudice to any other administrative or judicial remedy, you have the right to lodge a complaint with a supervisory authority, in particular in the country (such as EU Member State and UK) of your habitual residence, place of work or place of the alleged infringement if you are not satisfied with our response or think we are processing your personal data not in accordance with the law.
For a Promotion you have opted in, you have the option to opt out at any time from participation in such Promotion and the receipt of any related communications by unsubscribe instructions provided in the relevant communications, or by selecting not to receive communications from us where the relevant media service offers that option.
Unless you indicated otherwise at installation or chose not to receive push and local notifications, we may send push and local notifications to your Device concerning updates, events, and special offers for our mobile applications of the Services installed on your Device. Please note that you have the option of deactivating push and/or local notifications by changing the settings of the application or of your Device.
We take your privacy very seriously and employ reasonable administrative, physical, and electronic measures to safeguard information received from you and held by us against identity theft and unauthorized access or alteration. In addition, we will take reasonable steps to assure that third parties to whom we transfer any data will provide sufficient protection of your personal information. We do not and will not, at any time, request your credit card information, login password, or any national identification numbers in a non-secure or unsolicited communication (e.g., via e-mail, telephone, or mobile device).
We will make any legally required disclosures of any breach of the security, confidentiality, or integrity of your unencrypted electronically stored “personal data” or “personal information” (as defined in applicable statutes on security breach notification) to you via email or conspicuous posting on our website in the most expedient time possible and without unreasonable delay, consistent with (i) the legitimate needs of law enforcement; or (ii) any measures necessary to determine the scope of the breach and restore the reasonable integrity of the data system.
If you have any concerns with the way we collect and handle your personal information, or would like to correct or request that we delete such personal information held by us, please contact us. We will use commercially reasonable efforts to honor your request; please note, though, that at a minimum we may retain an archived copy of your records as required by law or to send necessary communications to you under this Privacy Policy. You understand that deletion of your personal information may result in you not being able to view or use portions of our Services that depend on such information.
Our Services may contain links to other websites and online services or offers from third parties. For example, our Services may include offers from third-party advertisers or the ability to engage in transactions with such entities. If you choose to participate in offer-linked information requests or “click on” an advertisement or another third-party link, you may be directed to that third party's website or service and/or be prompted to provide personal information in connection with such activity whose policies regarding the handling of personal data may differ from ours.
The fact that we allow linking to a third-party website or service (including Account System, and optional mobile application recovery services) is not an endorsement or representation of our affiliation with that third-party, nor is it an endorsement of such third party's privacy or information security policies or practices or their compliance with any laws. We do not exercise control over third-party websites or services, and this Privacy Policy does not apply to information you provide or collected by them. These other websites or services may place their own cookies or other tracking devices on your computer or mobile device, or collect data or solicit personal information from you. Other websites and services follow different rules regarding the use or disclosure of the personal information you submit to them. We encourage you to read the privacy policies or statements of the other websites and services you use and the terms of the offers in which you participate. You agree that we are not responsible for, nor will we be liable to you or any third party for, your interaction with such third parties or the information requests initiated by such third parties or the subsequent use, treatment, or dissemination of the information you provide to them.
To the extent that any of our mobile applications of the Services collects personally identifiable information, that is done only as strictly necessary to enable us to provide those Services (see The How, above), and this cannot be disabled by “do not track” or other mechanisms available via your mobile Device's browser.
If you have any questions, inquires, requests, or complaints concerning this Privacy Policy or our information collection practices, or wish to exercise any of your legal rights, please contact us at support@programmingzemi.com or by post Attn: DeNA Customer Support Center, Shibuya Scramble Square, 2-24-12 Shibuya, Shibuya-ku, Tokyo 150-6140 JAPAN.
To communicate with our Data Protection Officer, please email to dpo[at]dena.com
*Please replace [at] with @.
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App Store は Apple Inc. のサービスマークです。
IOS商標は、米国Ciscoのライセンスに基づき使用されています。
Mac および macOS は米国その他の国で登録された Apple Inc. の商標です。
Google、Google ロゴ、Google Play、Google Play ロゴ、Google Classroom、Android および Android ロゴは Google LLC の登録商標です。
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