This video game (hereinafter Game and/or Application) is owned and operated by SUNCORPORATION, a company organised under the laws of Japan, with address of 250 Asahi, Kochino-Cho, Konan-City, Aichi, Japan (hereinafter the Company or SUNCORPORATION).

SUNCORPORATION undertakes, within the framework of its activities and in accordance with the regulations applicable in Japan and around the world, and in particular the European Data Protection Regulation (hereinafter referred to as the "GDPR"), to ensure the protection, confidentiality and security of the personal data of its users, customers, prospects and suppliers, and to respect their privacy. SUNCORPORATION also undertakes to implement the Japanese law, "Act on the Protection of Personal Information".

This Personal Data Protection Policy may be subject to change. SUNCORPORATION may at any time modify this Personal Data Protection Policy, in particular to adapt to the applicable legislation. These modifications are brought to the attention of the users of the Game. We recommend that you regularly review the current available version.
Our Game is not intended for minors, except with the authorization of their legal representatives provided by email or letter addressed to our Data Protection Officer, thereafter " DPO ".

DPO:E-mail: pmark_info@sun-denshi.co.jp
Post: SUNCORPORATION, NAGOYA BUILDING SAKURA-KAN 2F, 4-2-25,
Meieki, Nakamura-ku Nagoya-shi, Aichi 450-0002 Japan

• • I. Summary of our policy
    a. We collect your personal data
    
    • Information with regard to Users' Smartphones, namely, the identification numbers of the Users' Smartphones, the versions of the operation systems of the Users' Smartphones and User's IP address;
      Users' Email addresses;
      Users' Purchase history;
      Account information which is necessary for data migration to other smartphones (the "Accounts Information for Data Migration");
      Log files and crash reports, and other similar information;
      Log files which record information about the technical events which take place when the you play the Game;
      Information about your saving progress, in-game ranking, matchmaking with other users and other users which you have matched;
      Information relating to all your activities within Games.
      Statistical data about your play of the Games (Ex. Information about your progress within the Games, how long you spent on playing the games, character which you select, how you interact with other users, and matchmaking);
      
  • b. We process your personal data for these purposes
    
    • 1. To identify Users and to verify identity of Users;
      2. To enable Users to enjoy Game;
      3. To provide services customized to the Users' usage;
      4. To respond to inquiries from Users or to provide support for Users.
      5. To send push-type notices to Users' Smartphones (only to smartphones configurated to receive push-type notices);
      6. To distribute and display advertisements for the Company and for third parties, customized to Users, and to assess the impact of these advertisements;
      7. To correct malfunctions, bugs or failures in the Application if any;
      8. To analyse and make statistical analysis of the Users' utilization of the Application;
      9. To gather statistical information in which individuals/Users cannot be identified, and to provide them to third parties;
      10. To develop and improve Games;
      11. To enable User to migrate account information to other smartphones:
      
  • c. For these purposes, the legal bases are
    
    • 1. Legitimate interest: SUNCORPORATION needs to provide support for the Game and respond to inquiries from the users (that's why there is a legitimate interest to identify and verify identity of users)
      2. Consent: improving users' experience of our game is important (that's why we collect users' data, but users' consent is required)
      3. Consent: push-type notices are useful for users (but users' consent is required)
      4. Consent: third parties' cookies allow SUNCORPORATION and its partners to provide adapted advertisement.
      5. Legitimate interest: correction of malfunctions/failures/bugs is essential for the Company and the users, especially for security matters.
      6. Consent: surveying the way users use the Application allow the Company to adapt the Game to the users' preferences (but users' consent is required)
      7. Legitimate interest: gathering statistical information in which individuals/Users cannot be identified is necessary to understand the habits of users
      8. Legitimate interest & legal obligations: SUNCORPORATION needs to remain at the disposal of users for questions or support issues (for technical or security issues as well)
      
  • d. Data retention period of your personal data
    
    • For each personal data we collect, the data retention period is set as below.
      For information with regard to Users' Smartphones, namely, the identification numbers of the Users' Smartphones, the versions of the operation systems of the Users' Smartphones, the data is retained throughout the period when you are using Games;
      For email addresses to be used for sending email for Users' support, the data is retained throughout the period when you are using Games;
      For purchase history, the data is retained throughout the period when you are using Games;
      For account information which is necessary for data migration to other smartphones (the "Accounts Information for Data Migration"), the data is retained throughout the period when you are using Games.
      
  • e. You have rights related to your personal data
    
    • You have a right to:
      1. Access to your personal data (Article 15 of the GDPR)
      2. Request corrections if the data is found to be inaccurate (Article 16 of the GDPR)
      3. Object to the processing of your personal data (Article 21 of the GDPR)
      4. Erasure of your personal data (Article 17 of the GDPR)
      5. Restrict the processing of your personal data (Article 18 of the GDPR)
      6. Ask for the data portability of your personal data (Article 20 of the GDPR)
      
  • f. To exercise your rights, your request must be sent
    
    • By email to: pmark_info@sun-denshi.co.jp
      Or by post/air mail to: SUNCORPORATION, GLOBAL GATE 20F, 4-60-12,
      Hiraikecho, Nakamura-ku Nagoya-shi, Aichi 453-6120 Japan
      
      We will keep the communications relating to your request as evidence of our response in connection to the exercise of your Rights in order to provide them to the control authorities (legitimate interest and legal obligation) if need be.
      We may need to confirm your identity.
      
  • g. Your personal data deserve appropriate technical and organisational measures
    
    • In accordance with Article 34 of the General Data Protection Regulations, you will be notified as soon as possible of any breach that may compromise the security of your personal data (such as leak, alteration, loss, etc.).
      
  • h. Cookies
    
    • See the information banner appearing at the bottom of the page for the data migration when you migrate account information to other smartphones.
      Please refer to our cookie management policy (URL: https://www.sun-denshi.co.jp/eng/privacy/ ).
      
  • II. Our policy in detail
    a. Minimization of collected data
    
    • SUNCORPORATION only processes the personal data that is needed for the purposes of the Game, and SUNCORPORATION only uses the data for those purposes (defined in II.e).
      SUNCORPORATION considers data protection issues as part of the design and implementation of its services and of the Game. We process this data with due regard for legality, fairness and transparency. We are committed to be as clear, open and honest as possible from the outset so that you can easily understand what we are doing with your personal data.
      
  • b. Sharing your data with third parties and transfer of your data outside the European Union
    
    • SUNCORPORATION is a Japanese company. Your personal data are hosted in Japan.
      
      Japan has been considered as a country offering an adequate level of protection, according to the " Joint Statement by Haruhi Kumazawa, Commissioner of the Personal Information Protection Commission of Japan and Věra Jourová, Commissioner for Justice, Consumers and Gender Equality of the European Commission ".
      We may, however, need to transfer your data, if necessary, to authorized third parties.
      
  • c. Security of your data
    
    • According to article 32 of the GDPR, SUNCORPORATION takes appropriate security measures to protect your personal data:
      Personal Data is stored behind a firewall to protect it from unauthorized access or against loss, misuse or alteration and maintain the firewall;
      Personal Data stored in a database is accessible to authorized employee on a need-to-know base only;
      Users or authorized employees must have a unique identification number and password before gaining access to Personal Data;
      By using SSL communication means, communication of personal data is encrypted;
      For information with regard to Users' Smartphones, namely, the identification numbers of the Users' Smartphones, the versions of the operation systems of the Users' Smartphones, the data is retained throughout the period when User are using Games and for a while afterwards;
      Company maintains written security policies to which all employees must comply:
      
  • d. Data concerning minors
    
    • As a matter of principle, we do not process data from minors under the age of 16.
      Our game is not intended for minors except with the authorization of their legal representatives provided by email or letter addressed to our DPO.
      
  • e. Processing of personal data carried out by SUNCORPORATION
    
    • We process your personal data for these purposes:
      1. To identify Users and to verify identity of Users;
      2. To enable Users to enjoy Game;
      3. To provide services customized to the Users' usage;
      4. To respond to inquiries from Users or to provide support for Users.
      5. To send push-type notices to Users' Smartphones (only to smartphones configurated to receive push-type notices);
      6. To distribute and display advertisements for the Company and for third parties, customized to Users, and to assess the impact of these advertisements;
      7. To correct malfunctions, bugs or failures in the Application if any;
      8. To analyse and make statistical analysis of the Users' utilization of the Application;
      9. To gather statistical information in which individuals/Users cannot be identified, and to provide them to third parties;
      10. To develop and improve Games;
      11. To enable User to migrate account information to other smartphones:
      
      The data we collect for these purposes are as follows:
      To identify Users and to verify of Users and to send push-type notices to Users' Smartphones (only to smartphones configurated to receive push-type notices), we collect information with regard to Users' Smartphones, namely, the identification numbers of the Users' Smartphones, the versions of the operation systems of the Users' Smartphones and Users' IP address (automatically);
      To provide services customized to the User's usage, to distribute and display advertisement customized to User, and to respond to inquiries from Users or to provide support for Users, we collect email addresses (when each of you inputs an email address);
      To distribute and display advertisement customized to User and to assess the impact of these advertisement, we collect purchase history (automatically);
      To enable User to migrate account information to other smartphones, we collect Users' account information which is necessary for data migration to other smartphones (the "Accounts Information for Data Migration") (when you migrate data to other smartphones);
      To correct malfunctions, bugs or failures in the Application, we collect log files and crash reports, and other similar information (automatically);
      To enable Users to enjoy Games, we collect log files which record information about the technical events which take place when you play the Game (automatically);
      To enable Users to enjoy Games, we collect Users' information about saving progress, in-game ranking, matchmaking with other users and other users which you have matched (automatically);
      To analyse and make statistical analysis of the Users' utilization of the Application, and to gather statistical information in which individuals/Users cannot be identified, and to provide them to third parties, we collect Users' information relating to all your activities within the Games (automatically).
      To develop and improve Games, we collect statistical data about your play of the Games (Ex. Information about your progress within the Games, How long you spent on playing the games, Character which you select, How you interact with other users, Matchmaking) (automatically);
      
      To install/display the Game onto your Smartphone from online stores, namely, Google LLC (Google Play) and Apple Inc. (App Store), they may collect your personal information, in particular to suggest updates or security patches. They also use this personal information for their own purpose subject to their own privacy policies. When you use these online stores, you should read their privacy policies and agree to them.
      
      The legal bases for these purposes are as follows:
      1. Legitimate interest: SUNCORPORATION needs to provide support for the Game and respond to inquiries from the users (that's why there is a legitimate interest to identify and verify identity of users)
      2. Consent: improving users' experience of our game is important (that's why we collect users' data, but users' consent is required)
      3. Consent: push-type notices are useful for users (but users' consent is required)
      4. Consent: third parties' cookies allow SUNCORPORATION and its partners to provide adapted advertisement.
      5. Legitimate interest: correction of malfunctions/failures/bugs is essential for the Company and the users, especially for security matters.
      6. Consent: surveying the way users use the Application allow the Company to adapt the Game to the users' preferences (but users' consent is required)
      7. Legitimate interest: gathering statistical information in which individuals/Users cannot be identified is necessary to understand the habits of users
      8. Legitimate interest & legal obligations: SUNCORPORATION needs to remain at the disposal of users for questions or support issues (for technical or security issues as well)
      
  • f. Data retention period of your personal data:
    
    • ・For each personal data we collect, the data retention period is set as below.
      ・For information with regard to Users' Smartphones, namely, the identification numbers of the Users' Smartphones, the versions of the operation systems of the Users' Smartphones, the data is retained throughout the period when you are using Games and for a while afterwards in order to provide Game and its related services;
      ・For email addresses to be used for sending email for Users' support, the data is retained throughout the period when you are using Games in order to provide Game and its related services;
      ・For purchase history, the data is retained throughout the period when you are using Games in order to provide Game and its related services;
      ・For account information which is necessary for data migration to other smartphones (the "Accounts Information for Data Migration"), the data is retained throughout the period when you are using Games in order to provide Game and its related services:
      
  • g. Exercise your rights considering your personal data:
    
    • In accordance with the GDPR, You have a right to:
      1. Access to your personal data (Article 15 of the GDPR)
      2. Request corrections if the data is found to be inaccurate (Article 16 of the GDPR)
      3. Object to the processing of your personal data (Article 21 of the GDPR)
      4. Erasure of your personal data (Article 17 of the GDPR)
      5. Restrict the processing of your personal data (Article 18 of the GDPR)
      6. Ask for the data portability of your personal data (Article 20 of the GDPR)
      
      When you exercise your rights, our Data Protection Officer will process your personal data for the purpose of managing your request (title, surname, first name, potentially copy of identity document, nature of the request, response provided). This data is kept for a period of three (3) years, with the exception of the copy of your identity document (if requested), which is kept for one (1) year.
      
      For any information, or to exercise your rights regarding the processing of your personal data by SUNCORPORATION, you may contact our DPO:
      
      By email at the following email address:
      pmark_info@sun-denshi.co.jp
      By post/Air mail at the following address: SUNCORPORATION, GLOBAL GATE 20F,
      4-60-12, Hiraikecho, Nakamura-ku, Nagoya-shi, Aichi 453-6120 Japan
      
      Our DPO may ask additional information in order to confirm your identity when you file a request to exercise your rights. For instance, our DPO/Privacy manager may ask that you send a copy of an official ID such as an Identity card or passport.
      
      You also have the right to refer any complaint relating to the way in which SUNCORPORATION collects and processes your data to the Japanese Personal information Protection Commission (PPC) (link to complaint here) or to the National Authority in charge of Data Protection in your country.
  • h. Information on the management of cookies and trackers
    
    • For details on the management of cookies by SUNCORPORATION in connection with the Game, please refer to our cookie management policy (URL: https://www.sun-denshi.co.jp/eng/privacy/ ).
      
  • i. Links to third party companies
    
    • The SUNCORPORATION game may contain links to social media platforms managed on third party servers run by persons or organizations over which the company has no control.
      As such, SUNCORPORATION cannot be held responsible for the way your data is stored or used on these third-party servers. We advise you to read the applicable personal data protection policy of each third-party website to which you access via our website/Game, in order to assess the way in which your personal data will be used.
      
  • j. Changes to this policy
    
    • SUNCORPORATION may change this privacy policy from time to time.
      This privacy policy has been approved by our DPO before its release.