GAME

Effective date: February 26, 2026

Global Privacy Policy for “KASSO GAIDEN: Escape from the Skaterverse”

TOKYO BROADCASTING SYSTEM TELEVISION, INC. (“TBS ,” “we,” or “our) processes the personal information of users (“Users”) of our service “KASSO GAIDEN: Escape from the Skaterverse” (the “Service”), and Users are also referred to as “Data Subjects,” (unless specified otherwise) as follows.

1. To whom this Global Privacy Policy applies?
   This Global Privacy Policy applies to Users who are based outside of Japan.
   Note on minors: our Services are intended for individuals who are 13 years of age or older.
   If you are a resident of the following countries, you may have certain rights with respect to your personal information, please see the following links below.
   ・United States
   ・the European Economic Area (“EEA“) and the United Kingdom (“UK“)
   ・Brazil
   
2. What personal information do we collect?
   We process the following personal information.
   
   – Account information: Your year and month of birth, age, user name, in-game ID, email address
   　and password
   – Online identifiers and device information: IP addresses, device product number, linked account
   　data, authentication information, other online identifiers, and other information obtained from
   　your device such as operating system and language;
   – Commercial Information: we may collect details of the services we have provided to you, or that
   　you’ve enquired about, including any additional information necessary to deliver those services
   　and respond to your enquiries.
   – Gameplay information: scores, stages cleared, playtime and information for game continuation;
   – Transaction information: your account’s purchase information of additional stages; and
   – Communications information: Any emails or other communications you may send us.
   – Other personal information required to pursue the purposes of use specified in “3.How do we use
   　personal information?” below.
   
3. How do we collect personal information?
   We obtain the Data Subject’s personal information directly from the Data Subject (including cases where personal information is automatically obtained). However, we may obtain the Data Subject’s personal information indirectly from a third party in the following cases:
   – When obtaining personal information from third party companies (including acquisition from companies that operate platforms for distributing Service);
   
4. How do we use personal information? / Legal basis for processing
   We process personal information for the purposes and legal bases set forth below, to the extent that such legal basis is required and applicable under the applicable data protection regulations.
   Depending on the User’s location and applicable data protection laws, additional/other legal basis for processing may apply.

Purpose for processing	Legal basis for processing
We use your account information, online identifiers and device information, gameplay information and transaction information to provide our Service to you (including settings for game continuation) including registering you for the Service and ranking scores.	Contractual performance to provide and operate the Service, as long as processing of personal information is necessary for the performance of a contract.
We may use your account information and online and device information to verify your identity	Legitimate interest pursued by TBS to ensure the security of our Service and data and to ensure only users over 13 age can access the Service.
We use your account information and transaction information to facilitate and manage your purchase of additional stages.	Contractual performance to provide and operate the Service, as long as processing of personal information is necessary for the performance of a contract.
We use your account information, online identifiers and device information, and gameplay information to maintain your game data for managing use information, including restoring game data in the event of device changes	Contractual performance to provide and operate the Service, as long as processing of personal information is necessary for the performance of a contract.
We use your account information, online identifiers and device information, and gameplay information to ensure the security and integrity of the Service, to debug, and to repair errors.	Legitimate interest pursued by TBS to protect, maintain and improve the Service and to prevent or detect fraud. In the UK where it is necessary to process personal data to prevent, detect, or investigate a crime, TBS relies on our recognised legitimate interests.
We use your account information, transaction information and communications information to respond to customer inquiries.	Legitimate interest pursued by TBS to manage our relationship with you and provide support in relation to the Service.
We use your account information, online identifiers and device information, gameplay information and transaction information to monitor compliance with and enforce TBS’s terms and conditions, policies, etc. in relation to the Service.	Legitimate interest pursued by TBS to protect our business interests and maintain a fair gaming environment. Legal obligation under each applicable laws and regulations, if it is necessary to process personal information to comply with applicable local laws and regulations.
We use your personal information to perform a corporate transaction such as if we acquire assets of another business, or sell or transfer all or a portion of our business or assets including through a sale in connection with a bankruptcy and other forms of corporate change	Legitimate interest pursued by TBS.
We use your personal information to achieve other purposes permitted under applicable laws.	Legitimate interest pursued by TBS. Other applicable legal basis.

The provision of personal information may be mandatory for various reasons, such as being a statutory or contractual requirement or being a necessary condition for entering into a contract. Where the provision of personal information, is mandatory this will be made clear when we collect it, and we will not be able to provide you services if you don’t provide such personal information.

5. How long do we retain your personal information?
   In order to decide the appropriate retention period for personal information, we consider the following: the volume, nature, and confidentiality of the personal information; the potential risk of damage caused by unjust use or disclosure of the personal information; the purposes for which we process the personal information, and whether TBS can achieve those purposes by other means; and applicable legal requirements. If the Data Subject’s personal information collected by us is no longer necessary, we will delete or anonymize the personal information or, if such measures are impracticable (for example, if the personal information has been stored in back-up archives), we will safely retain the Data Subject’s personal information until its deletion becomes practicable and ensure that any new processing with respect to the Data Subject’s personal information will not be conducted.
   Of the information collected, all information other than email addresses and detailed information on additional stage purchases will be deleted three months after the Services are discontinued.
   
6. With whom do we share personal information?
   We may disclose personal information, as outlined in Section 2 “What personal information do we collect?” above, with third parties in the following cases:
   Disclosing of personal information with third party service providers who perform functions on our behalf such as website hosting, customer service operations, identity checking, sending e-mails, and processing payments;
   – Disclosing of personal information with third parties (controllers) necessary for operating Service;
   – Disclosing of personal information to third parties associated with the corporate sale, merger,
   　acquisition, or other transfer of all or part of our assets with our advisers and the prospective
   　buyer/seller’s advisers;
   – Disclosing of personal information to law enforcement, government agencies and other third
   　parties that is required by laws or orders of governmental agencies and the like.
   – Disclosing of personal information with a third party that is (i) necessary for the protection of the
   　life, body, or property of TBS, the Data Subject, or a third party and (ii) permitted by applicable
   　data protection regulations, for example emergency services.
   – Disclosing of personal information that is otherwise permitted under applicable data protection
   　regulations.
   – Disclosing of personal information to other third parties with your consent.
   
7. How do we handle cross-border transfers of personal information?
   We may transfer personal information to foreign countries and jurisdictions, including the following, in order to fulfill the purposes stated in Section 3 “How do we use personal information?” above:
   – United States
   – Japan
   
   We may transfer email addresses and detailed records of additional stage purchases to countries in which servers of application provider platforms such as Apple or Google used for processing such data are located.
   
   Upon transferring personal information to any of the countries or regions, TBS takes appropriate protection measures required by the data protection regulations of that country or region.
   
   [If you are in the UK or the EU, and your personal information goes outside of the UK or the EU, the law requires us to take extra steps to make sure your personal data is protected in the place it is going to. We typically rely on adequacy decisions by the European Commission and UK Government or Standard Contractual Clauses to protect your personal information when transferred internationally.]
   
8. How do we implement safety management measures?
   We will take necessary and appropriate measures such as countermeasures against unauthorized access and computer viruses to prevent loss, destruction, falsification, leaking, and the like of personal information.
   We will exercise necessary and appropriate supervision over our employees, contractors, etc. to protect personal information of Users.
   
9. Data Subjects’ rights
   TBS respects the rights held by Data Subjects under the applicable data protection regulations of each country or region. For example, to the extent granted under the applicable data protection regulations of each country or region (such as in EU or UK), Data Subjects may have rights such as the following: right to access; right to rectification; right to erasure; right to restriction of processing; right to objection to processing; right to withdraw consent (this may be granted if the Data Subject has given consent regarding certain types of processing activities; however, the Data Subject’s withdrawal of consent does not affect the lawfulness of processing conducted based on the Data Subject’s consent before such withdrawal); right to data portability. Data subjects may also have the right to complain to TBS (see our contact details in Section 11 below) or a data protection authority. In the UK this would be the Information Commission(ico.org.uk), for those in the EU a list of data protection authorities can be found here.
   
   The Act on the Protection of Personal Information of Japan (“APPI”) grants the right to request the following in relation to Retained Personal information (as defined in Article 16, Paragraph 4 of the APPI): notification of the purpose of use; disclosure; correction, addition, or deletion of content; suspension of use, erasure, or suspension of third-party provision; and disclosure of records of third-party provision (meaning records of third-party provision as prescribed in Article 37, Paragraph 2 of the APPI).
   Any Data Subject wishing to exercise the Data Subject’s rights granted under the data protection regulations of the country or region in question may contact us using the contact details stated in Section 11 “Contact details” below.
   
10. Third-party services
    Our Services may contain references and/or links to third-party websites and services. We are not responsible for any third party’s data collection or privacy practices, and we have no control over what information third parties track or collect. Any access to and use of such linked websites is not governed by this Policy but instead is governed by the privacy policies of those third-party websites. We encourage you to review the privacy policies posted on those third-party websites for further information.
    
11. Contact details
    For questions and inquiries regarding this Global Privacy Policy, please contact us using the following contact details:
    TBS Personal Information Management Office
    E-mail: privacy@gr.tbs.co.jp
    Address: 5-3-6 Akasaka, Minato-ku, Tokyo 107-8006, Japan
    
12. How will you know if this Global Privacy Policy changes?
    We may amend all or part of, or make an addition to, this Global Privacy Policy by publishing that amendment or addition on our websites, or giving notice via any other method that we deem appropriate (such as via email). In such cases, the post-amendment version of this Global Privacy Policy will be applied from either the date stated in such notice or the date upon which a product or Service of us is used or our website is accessed for the first time following such notice, whichever is earlier.

Annex for residents of the EEA and the UK

This Annex applies to Data Subjects who are in the EEA or UK. It describes your data protection rights, including the right to object to some of the processing which we carry out. More information about your rights, and how to exercise them, is set out in Section 10 “Data subjects’ rights”.

Controller
TBS is the controller of personal information processed in line with the purposes as stated in the Global Privacy Policy and this Annex.

Legitimate Interests
There are instances where we have a legitimate interest to use your data. Our legitimate interest will vary depending on what we are using your data for, and we explain above what the interest is and how it relates to the processing operations that we are carrying out. Where we process personal data on the basis of a legitimate interest, then – as required by data protection law – we have carried out a balancing test to document our interests, to consider what the impact of the processing will be on individuals and to determine whether individuals’ interests outweigh our interests in the processing taking place. In the UK, we do not need to conduct a balancing test if we process personal data for a “recognised legitimate interest.” You can obtain more information about this balancing test by using the contact details in Section 10 “Contact details” above.

International Transfers
If you are in the UK or the EU, and your personal information goes outside of the UK or the EU, the law requires us to take extra steps to make sure your personal data is protected in the place it is going to. We typically rely on adequacy decisions by the European Commission and UK Government or Standard Contractual Clauses to protect your personal information when transferred internationally.

EEA & UK Representatives
We do not have an establishment in the European Union; therefore, we have appointed a local representative, DataRep, who you can contact. Our EU representative can be contacted directly by (i) emailing them at the following address [datarequest@datarep.com] quoting <TOKYO BROADCASTING SYSTEM TELEVISION , INC.> in the subject line or (ii) submitting the online webform at www.datarep.com/data-request.

We do not have an establishment in the United Kingdom, therefore, we have appointed a local representative, DataRep, who you can contact. Our UK representative can be contacted directly by (i) emailing them at the following address [datarequest@datarep.com] quoting <TOKYO BROADCASTING SYSTEM TELEVISION , INC.> in the subject line or (ii) submitting the online webform at www.datarep.com/data-request.

Annex for residents of the U.S. state

Children’s Privacy
Our Services are not intended for children under 13 years of age. If you are under 13, do not use our Services. If we learn we have collected or received personal information from a child under 13, we will delete that information. If you believe we might have any information from or about a child under 13, please contact us at kassogaiden-cs@gr.tbs.co.jp.

Additional California privacy disclosures
These Additional California Privacy Disclosures supplement the information contained in the Policy. These Disclosures apply only to individuals residing in California.

We may collect the following categories of information:

• Identifiers, such as your name, username, date of birth, and e-mail address;
• Commercial Information, we or our service providers may collect your financial information (e.g. your payment details), and details of the services we have provided to you, or that you’ve enquired about, including any additional information necessary to deliver those services and respond to your enquiries;
• Internet or other electronic network activity information, such asIP addresses, device identifiers, and other information obtained from your device; and

We do not collect Sensitive Personal Information.

Sale of personal information
We do not sell personal information for monetary consideration. However, our use of certain tracking-technologies may meet the definition of “selling” or “sharing” as that term is defined by applicable law. We may have sold or shared the following categories of personal information with our targeted advertising service providers and partners: Identifiers, and Internet Activity Information. We do not knowingly sell the personal information of minors under 16.

Use, disclosure, and retention of personal information
We may use and disclose personal information for the business and commercial purposes detailed in the “How do we use personal information?” and “With whom do we share personal information?” sections of the Policy.
We retain your information as described in the “How long do we retain your personal information?” section of the Policy.

Shine the Light
California Shine the Light: If you are a California resident, you may opt out of sharing your Personal Data subject to California Civil Code §1798.83 (the “Shine the Light law”) with third parties for those third parties’ direct marketing purposes by submitting a request to opt-out as in the Your California rights section below.

Your California rights
If you are a California resident, you may have the following rights with respect to the personal information we process about you:

• Right to Know and Access. You may have the right to request information about the categories of personal information we have collected about you, the categories of sources from which we collected the personal information, the purposes for collecting, selling, or sharing the personal information, and the categories of third parties to whom we have disclosed your personal information, and the specific pieces of personal information we have collected about you.
• Right to Delete. You may have the right to request that we delete personal information that we have collected from you.
• Right to Correct. You may have the right to request that we correct inaccurate personal information that we maintain about you.
• Right to Opt-out of Sales or Sharing. You may have the right to opt-out of the “sale” or “sharing” of your personal information as such terms are defined by the California Consumer Privacy Act. To opt out of targeted advertising contact us at privacy@gr.tbs.co.jp.
• Right to Non-Discrimination. Should you choose to exercise any of these rights, we will not discriminate against you in any way. If you exercise certain rights, understand certain features of the Website may be unavailable to you.

You can exercise these rights by using the information in the “Submitting a privacy rights request” section below.

Additional States’ rights
These Additional U.S. State Privacy Disclosures supplement the information contained in the Policy. These Disclosures apply only to residents of Nebraska, Texas, and Rhode Island.

Consumer privacy rights
You may have the following rights, subject to any applicable exemptions or limitations:

• Right to Access. You have the right to confirm whether we are processing your personal information and to access such personal information.

• Right to Correct. You have the right to request that we correct inaccurate personal information that we maintain about you.

• Right to Delete. You have the right to request that we delete your personal information under specific circumstances.

• Right to Opt-out. You have the right to object or opt-out of certain types of processing, including: (1) processing for the purpose of targeted advertising, and (2) processing for the purpose of the sale of personal information.

• Right to Data Portability. You have the right to request a copy of your personal information in an accessible format.

• Right to Equal Service. If you choose to exercise any of these rights, we will not discriminate against you in any way. If you exercise certain rights, understand that you may be unable to use or access certain features of our websites, services, or properties.

• Right to Appeal. If we do not grant your consumer request, you may have the right to appeal that denial.

You can exercise your privacy rights as described in “Submitting a privacy rights request,” below.

Submitting a privacy rights request
To exercise your rights, please submit a request to us by emailing us at kassogaiden-cs@gr.tbs.co.jp. Making a consumer request does not require you to create an account with us. Applicable law may limit the number of times that you can submit a particular request within a 12-month period.

You may be able to designate an authorized agent to make a request on your behalf. We may deny a request from an authorized agent that does not submit proof that they have been validly authorized to act on your behalf or if the agent attempt to exercise a right for which they are not legally authorized to do so.

Upon receiving your request to know, access, delete, or correct, we will need to verify your identity to determine that you are the same person about whom we have the information in our system. These verification efforts require us to ask you to provide information so that we can match it with information you have previously provided us. We may also use other verification methods as the circumstances dictate. We will only use personal information provided in your request to verify your identity or authority to make the request. To the extent possible, we will avoid requesting additional information from you for the purposes of verification. If we cannot verify your identity from the information already maintained by us, we may request that you provide additional information for the purposes of verifying your identity, and for security or fraud-prevention purposes. We may deny your request to know, access delete or correct if we cannot verify your identity.

Annex for residents of Brazil

If you are a User based in Brazil, the Brazilian Data Protection Law (Federal Law No. 13,709/2018 or LGPD) and the regulations issued by the Brazilian Data Protection Agency (ANPD) will apply to our data processing activities. In addition to the information provided in this Global Privacy Policy, we clarify the following:

Data controller information
For the purposes of this Global Privacy Policy, the data controller of your personal data is TBS Personal Information Management Office.

Data Subjects’ rights
In addition to the Data Subjects’ rights mentioned in Section 10, under the LGPD, Brazilian Users also have the right to request: (i) the anonymization, blocking, or deletion of data considered unnecessary, excessive, or processed in violation of the LGPD; (ii) data portability for data you have provided to us, if applicable; (iii) ask us for information about which public and private entities we have shared your data with; and (iv) clear information about the option of not providing consent and the consequences of withholding consent.

13.3. DPO contact information
If you have any questions, concerns, or requests regarding this Global Privacy Notice or your data, you can reach out to us through the following contact:
・E-mail: privacy@gr.tbs.co.jp (our dedicated privacy contact address)
・Data Protection Officer (DPO): our DPO is Takafumi Tsugawa. You may reach the DPO by emailing us at
　the address above.
・Mailing address: if you prefer to contact us via physical mail, please send correspondence to TBS
　Personal Information Management Office, 5-3-6 Akasaka, Minato-ku, Tokyo 107-8006, Japan.

Global Privacy Policy for “KASSO GAIDEN: Escape from the Skaterverse”

TOKYO BROADCASTING SYSTEM TELEVISION, INC. (“TBS ,” “we,” or “our) processes the personal information of users (“Users”) of our service “LAPPY GAMES” (the “Service”), and Users are also referred to as “Data Subjects,” (unless specified otherwise) as follows.

1. To whom this Global Privacy Policy applies?
This Global Privacy Policy applies to Users who are based outside of Japan.

2. What personal information do we collect?
We process the following personal information of Data Subjects.
Your user name, in-game ID, and any other information to setting for player matchmaking and game continuation
Online identifiers and device information (IP addresses, linked account data, authentication information, your account’s friends list and block list, and other online identifiers, and other information obtained from your device)
Other personal information required to pursue the purposes of use specified in “3.How do we use personal information?” below.

3. How do we use personal information?
We process personal information for the following purposes and other similar purposes permitted by applicable laws and regulations:
– To provide our Service to Users (including settings for player matchmaking and game continuation);
– To register Users for the Service and to verify Users’ identities;
– To ensure the security and integrity of the Service, to debug, and to repair errors;
– To respond to customer inquiries;
– To deal with any breach of any of TBS’s terms and conditions, policies, etc. (“Terms and Conditions, Etc.”) in relation to the Service; and
– For other purposes permitted under applicable laws and regulations.

4. Legal basis, etc. for processing
We process personal information in accordance with the legal basis under the applicable data protection regulations (such as Data Subjects’ consent, performance of contractual obligations, legitimate interests, and compliance with laws and regulations).
The provision of personal information may be mandatory for various reasons, such as being a statutory or contractual requirement or being a necessary condition for entering into a contract. The provision of personal information, as outlined in Section 2 “What personal information do we collect?” above, is a contractual requirement, and we will not be able to provide you services if you don’t provide such personal information.

5. How long do we retain your personal information?
Of the information collected, information other than the in-game ID is deleted each time a game session ends. In order to decide the appropriate retention period for personal information, we consider the following: the volume, nature, and confidentiality of the personal information; the potential risk of damage caused by unjust use or disclosure of the personal information; the purposes for which we process the personal information, and whether TBS can achieve those purposes by other means; and applicable legal requirements. If the Data Subject’s personal information collected by us is no longer necessary, we will delete or anonymize the personal information or, if such measures are impracticable (for example, if the personal information has been stored in back-up archives), we will safely retain the Data Subject’s personal information until its deletion becomes practicable and ensure that any new processing with respect to the Data Subject’s personal information will not be conducted.

6. How do we collect personal information?
We obtain the Data Subject’s personal information directly from the Data Subject (including cases where personal information is automatically obtained). However, we may obtain the Data Subject’s personal information indirectly from a third party in the following cases:
– When obtaining personal information from third party companies (including acquisition from companies that operate platforms for distributing Service);
– Any other cases where personal information is lawfully obtained from a third party ；

7. With whom do we share personal information?
We may share personal information, as outlined in Section 2 “What personal information do we collect?” above, with third parties in the following cases:
– Sharing of personal information with processors to fulfill the purposes stated in Section 3 “How do we use personal information?” above;
– Sharing of personal information with third parties (controllers) necessary for operating Service including Epic Games;
– Sharing of personal information associated with the corporate sale, merger, acquisition, or other transfer of all or part of our assets;
– Sharing of personal information that is required by laws or orders of governmental agencies and the like;
– Sharing of personal information with a third party that is (i) necessary for the protection of the life, body, or property of TBS, the Data Subject, or a third party and (ii) permitted by applicable data protection regulations; and
– Sharing of personal information that is otherwise permitted under applicable data protection regulations.

8. How do we handle cross-border transfers of personal information?
We may transfer personal information to foreign countries and jurisdictions, including the following, in order to fulfill the purposes stated in Section 3 “How do we use personal information?” above:

– United States
– Netherlands
– Japan

Upon transferring personal information to any of the countries or regions listed above, TBS takes appropriate protection measures required by the data protection regulations of that country or region.

9. How do we implement safety management measures?
We will take necessary and appropriate measures such as countermeasures against unauthorized access and computer viruses to prevent loss, destruction, falsification, leaking, and the like of personal information.
We will exercise necessary and appropriate supervision over our employees, contractors, etc. to protect personal information.

10. Data Subjects’ rights
TBS respects the rights held by Data Subjects under the applicable data protection regulations of each country or region. For example, to the extent granted under the applicable data protection regulations of each country or region, Data Subjects may have rights such as the following: right to access; right to rectification; right to erasure; right to restriction of processing; right to objection to processing; right to withdraw consent (this may be granted if the Data Subject has given consent regarding certain types of processing activities; however, the Data Subject’s withdrawal of consent does not affect the lawfulness of processing conducted based on the Data Subject’s consent before such withdrawal); right to data portability; and right not to be subject to automated decision-making. The Act on the Protection of Personal Information of Japan (“APPI”) grants the right to request the following in relation to Retained Personal information (as defined in Article 16, Paragraph 4 of the APPI): notification of the purpose of use; disclosure; correction, addition, or deletion of content; suspension of use, erasure, or suspension of third-party provision; and disclosure of records of third-party provision (meaning records of third-party provision as prescribed in Article 37, Paragraph 2 of the APPI).
Any Data Subject wishing to exercise the Data Subject’s rights granted under the data protection regulations of the country or region in question may contact us using the contact details stated in Section 11 “Contact details” below.

11. Contact details
For questions and inquiries regarding this Global Privacy Policy, please contact us using the following contact details:

TBS Personal Information Management Office
E-mail: privacy@gr.tbs.co.jp
Address: 5-3-6 Akasaka, Minato-ku, Tokyo 107-8006, Japan

12. How will you know if this Global Privacy Policy changes?
If we intend to amend this Global Privacy Policy, we may amend all or part of, or make an addition to, this Global Privacy Policy by publishing that amendment or addition on our websites, or giving notice via any other method that we deem appropriate. In such cases, the post-amendment version of this Global Privacy Policy will be applied from either the date stated in such notice or the date upon which a product or Service of us is used or our website is accessed for the first time following such notice, whichever is earlier.

Effective date: February 26, 2026

Global Teenager and Children’s Privacy Policy for “KASSO GAIDEN: Escape from the Skaterverse”

We’re TOKYO BROADCASTING SYSTEM TELEVISION, INC. or TBS for short. We’re the ones behind KASSO GAIDEN: Escape from the Skaterverse. This is our global privacy policy which explains what information we collect about you when you play our game, what we do with this and your rights (so things you can ask us to do with your information).
Note on minors: our Services are intended for individuals who are 13 years of age or older.

TL;DR

• We collect information from you when you create an account and play our game. This includes account information (age, date of birth, email, username), some online identifiers and information about the device (e.g. phone, PC) you use to play the game, information about your playing (score, stages cleared, playtime, save information), information on things you buy (such as extra stages) and your emails to us.
• We use this information to provide the game, set up your account, sell items to you, fix any issues, maintain the game and corporate transaction.
• We share this information with companies that provide services to us and government authorities when we have to under the law.
• Our Services may include links to other websites or services that we do not run. We do not control how they use your information, and we are not responsible for their privacy practices.
• We’re in Japan and so some of these other companies might also be here. We also transfer your information to the US.
• You have certain rights which help you control your information – you can use these rights by contacting us at privacy@gr.tbs.co.jp you can also ask us questions about how and what we use your information for.
• We do not have an office in the EU or UK, so you can contact DataRep.
  Email: datarequest@datarep.com
  Online form: www.datarep.com/data-request.

1. Who is this Global Privacy Policy For?
   We’ve written this policy to explain to people outside of Japan who use and access our game how we collect and use their personal information. If you’re an adult or just want to read the longer version click here.
   
2. What personal information do we collect?
   We collect personal information from you when you sign up and play our game. Some of this we ask you for and some of it we collect ourselves automatically. This information includes:

• Your account details: Your date of birth, age, user name, in-game ID, email address and password
• Online identifiers and device information: technical IDs given to your phone/laptop/PC (such as IP addresses, device product number, linked account data, authentication information, other online identifiers), authentication information (this is what proves it’s really you) and details of your device (like the operating system and language you have selected);
• Commercial Information: Any details of the services we have provided to you, or that you’ve enquired about, including any additional information necessary to deliver those services and respond to your enquiries.
• Game activity: interactions of you and your character in the game from which it’s possible to work out things about you such asscores, stages cleared, how long you’ve played for and information we need so you can continue the game next time you play;
• Purchase information: records of any additional stages you’ve bought
• Communications information: Any emails or other messages you may send us.
  
  Sometimes you have to provide this information as we need it to comply with the law or to provide the game and your purchases. We will make it clear if you must provide the information (mandatory) or if you can choose not to (optional). If information is mandatory and you don’t provide it we won’t be able to set up your account, let you play the game or make any purchases.

3. How do we use your personal information?
   In some countries like those in Europe we’re only allowed to use your personal information if a “legal basis” allows us to. These are legal bases we could use:

Legal Basis	When does this legal basis apply?
“Contract” We need to carry out or sign up to a contract	When it’s necessary to use your personal information to do what we agreed to do as part of our contract with you, or because you have asked us to do something before signing a contract with you and we need to use your personal information for this. In these cases, if you don’t provide your personal information, then we won’t be able to perform the contract or do what you have asked us to do before signing the contract.
“Legitimate Interest” It’s in our or someone else’s “legitimate interests”	“Legitimate interests” is a legal phrase. It usually means a commercial or business interest that is important to us or another company, and which we’ve balanced against your right to privacy. We will tell you what the interest is, and you can object to us using your personal information for this via email at [Email] or you can ask us how we balanced our interest against your right to privacy.
“Consent” You have given us your consent	Sometimes we will ask for your (or we might need to ask for your parent’s) consent to use your personal information. This consent will always be clear and separated out from other information we give you. You can always withdraw (take back) your consent by contacting us at privacy@gr.tbs.co.jp.
“Legal obligation” We need to do something a legal obligation tells us to	When it’s necessary to use your personal information so that we can perform our legal and regulatory obligations – so that we don’t break the law.

This next table tells you what personal information we use, why and which of the legal bases we use for this.

What we use	Why we use it	Our legal basis
Account details Online identifiers and device information Game activity Purchase information	To provide the game, save your progress, rank your scores and set up your account	Contract
Account details Online identifiers and device information	To confirm you are who you say you are.	Legitimate interest – our interest in making sure the game and our systems are secure and ensure age requirement.
Account detailsPurchase information	To handle your purchases of additional stages and have a record of what you buy from us.	Contract
Account details Online identifiers and device information Game activity	To save your game progress so you can restore this when you next log in or if you change the device you play on.	Contract
Account details Online identifiers and device information Game activity	To keep the game secure, improve the game and fix any issues.	Legitimate interest – our interest in protecting the game and improving your and other player’s future experiences with the game. In the UK we have a recognised legitimate interest where we use your personal information to stop criminals including detecting, investigating and preventing crime.
Account details Purchase information Communications information	To help you when you need support by answering questions and fixing issues	Legitimate interest – to answer your questions and help you with any issues with the game.
Account details Online identifiers and device information Game activity Purchase information	To make sure you and others are playing by our rules (such as our terms and conditions and policies).	Legitimate interest – to protect our business and maintain a fair gaming environment.
Online identifiers and device information Purchase information	To complete our financial reporting and disclosure obligations to tax agencies and regulators.	Legal obligation – our obligations under tax and corporate laws.
Account details Online identifiers and device information Game activity Purchase information Communications information	To send legal reports or respond to court orders/requests from law enforcement bodies.	Legal obligation – our obligationsunder intelligence and security laws.
Account details Online identifiers and device information Game activity Purchase information Communications information	To perform a corporate transaction.	Legitimate interest – to manage our company.
Account details Online identifiers and device information Game activity Purchase information Communications information	To achieve other purposes permitted under applicable laws	Legitimate interest – to manage our company. Other applicable legal basis.

4. How long do we keep your personal information for?
   We only keep your personal data for as long as we need it based on what the information is, why we use it, and what the law says. If we don’t need it any more we either delete it (get rid of it) or anonymise it (make it so you can’t be linked to it). Generally, we delete all information apart from your email address and information on your purchases 3 months after the Services are stopped.
   
5. Who do we share your personal information with?
   Sometimes we share your personal information with other companies and organisations.
   We may share your personal information, with third parties in the following cases:

• Service providers who help us run the game – these are companies that provide services to us such as hosting our website, checking identities on our behalf and processing payments;
• Third parties (controllers) – these are companies that necessary for operating services;
• If our company is sold, buys another or is merged – we may share personal information associated with the corporate sale, merger, acquisition, or other transfer of all or part of our assets with our advisers and the company planning to buy us (or sell us another company) and their advisers;
• When the law requires it – sharing of personal information that is required by laws or orders of governmental agencies and the like; and
• In emergencies – we may share your information if we need to protect you or another person, to protect us and our property and the law allows this sharing, for example we might share information with emergency services such as the police if we think you’re in danger.
• Consent – we may share your information if you consent.

6. Do we send your information to other countries?
   Yes sometimes. We’re in Japan and collect information directly from you but sometimes we send your information to other companies in Japan and the US for example to store your information. We send your email addresses and records of your stage purchases to countries where the servers of app stores such as Apple or Google are located.
   
   We take steps to protect your information when we send it to other countries. If you are in the UK or the EU, and we send your information to another country the law requires us to take extra steps to make sure your personal data is protected in the place it is going to. We typically rely on adequacy decisions by the European Commission and UK Government (decisions that say the other country can be trusted to respect your information) or Standard Contractual Clauses (special approved contracts that ensure the companies involved protect your personal information) to protect your personal information when transferred internationally.
   
7. How do we keep your information safe?
   We will take necessary and appropriate measures such as countermeasures against unauthorized access and computer viruses to prevent the loss, destruction, falsification, and leaking of personal information.
   We are careful to supervise people who work for us to make sure your personal information is protected.
   
8. Your rights – what you can do with your information
   Some countries have granted you rights over your personal information. These change from country to country but you may have the right to:

• See your information – you can ask us for a copy of the information we have about you (right of access)
• Fix mistakes – if something’s wrong or missing you can ask us to correct it (right of rectification/correction)
• Delete your information – in some cases you can ask us to delete your information (right of erasure)
• Stop certain uses of your information – you can object to our use of your personal information (right to object)
• Move your information elsewhere – you can ask us to give you your information in a format that can be sent to another company or ask us to send it to them directly (right of portability)
• Right to change your mind – if we asked for your consent/permission to use your information you can withdraw (takeback) your consent
  
  If you’re not happy – you can complain to use by emailing privacy@gr.tbs.co.jp. You can also complain to regulators (the organisations which enforce data protection laws). In the UK this would be the Information Commission (ico.org.uk) and in the EU you can find a list of regulators here.
  
  If you want to make any requests of us (exercise any of the rights above) just email us at privacy@gr.tbs.co.jp

9. Third-party services
   Our Services may include links to other websites or services that we do not run. If you click on those links, the other websites may collect information about you. We do not control how they use your information and we are not responsible for their privacy practices. This Privacy Policy does not apply to those other websites.
   
10. How to contact us
    You can contact us with any questions or complaints about your personal data and this privacy policy at:
    TBS Personal Information Management Office
    E-mail: privacy@gr.tbs.co.jp
    Address: 5-3-6 Akasaka, Minato-ku, Tokyo 107-8006, Japan
    
    We do not have an office in the EU, so we have chosen a company called DataRep to act as our representative there.
    If you live in the EU, you can contact DataRep for privacy questions by:
    ・Sending an email to datarequest@datarep.com
    　(Please write “TOKYO BROADCASTING SYSTEM TELEVISION, INC.” in the subject line), or
    ・Filling in the online form at www.datarep.com/data-request.
    
    We also do not have an office in the UK, so DataRep acts as our representative there as well.
    If you live in the UK, you can contact DataRep in the same way using the email address or website above.
    
11. Will this policy change?
    We may make changes to this policy by putting a new version on our website or notifying you of the changes (for example by email or a notification on the website). The date at the top of this policy tells you when this version applies from.