Privacy Policy

Koei Tecmo Games Co., Ltd. ("Koei Tecmo" or "we" or "our" or "us") take your privacy very seriously and are committed to process your personal data in transparent, fair, and secure ways. As you use our game titled "Atelier Resleriana: Forgotten Alchemy and the Polar Night Liberator" including its websites ("the Services"), we collect, use and share with third-parties certain personal data about you.

This Privacy Policy is intended to provide you with information on how, why and on what ground we collect, use, and share your personal data and the legal rights you can exercise on your personal data. By using our Services, you consent to this Privacy Policy and our collection, using and sharing your personal data, and other activities as described. If you do not agree to this Privacy Policy, please uninstall, and discontinue use of the Services.

The following country-specific exhibit may also apply to you depending on the area in which you reside or are located, so please refer to the country-specific exhibit. If this main text of the Privacy Policy conflicts with the exhibit, then the exhibit will prevail to the extent that such conflict exists.

• - Exhibit: EEA (European Economic Area) and the UK
• - Exhibit: U.S.

Please note that “personal data” in 2, 3, and 10 below shall include “personal information” under the meaning of Act on Protection of Personal Information of Japan.

We may modify, add to, or delete part of this policy from time to time. We will notify you of any such update by the method of email, posting on the official website, or notice inside the Services.

1. Who is responsible

This Privacy Policy is issued on behalf of KOEI TECMO GAMES CO., LTD., which is the controller within the meaning of the GDPR and is responsible for collecting and using your personal data in the context of providing the Services.

2. What personal data we collect

• 2.1 As you access and use the Services, we collect and use the following personal data about you, including in the past 12 months:
  • 2.1.1 Identification data: user ID, username, country of residence,
  • 2.1.2 Preference data: language and other preferences,
  • 2.1.3 Online activity log: your activity records in the Services, including date and time, type of action you take, your IP address, device identifier, OS type and version, and purchase record,
  • 2.1.4 Inquiry data: your identification (e.g., name, email address, etc.), the services you use, or you are interested in, your environment (platform, device model, OS type and version, etc.) and your messages and/or questions, and
  • 2.1.5 Device analytics and diagnostics data: your device's performance data, crash data, etc.
  • 2.1.6 Any other personal data required for the purposes set out in "3." of this Privacy Policy
• 2.2 The provision of personal data may be requisite for various reasons, such as being a statutory or contractual requirement or being a necessary condition for entering into a contract. If you do not provide certain personal data, we may be unable to provide you with the Services or respond to your inquiries with appropriate and precise information.
• 2.3 When you use or interact with third-party services that may be available on our Services, such as third-party social media widgets, share buttons, and/or login mechanisms, this Privacy Policy does not and will not extend to such features, which shall be subject to the respective third-party privacy policies.

3. How we use your personal data and how we collect it

• 3.1 We use your personal data for the following purposes:
  • 3.1.1 to provide you the Services of your choice,
  • 3.1.2 to deliver non-personalized advertising content relevant to the Services,
  • 3.1.3 to analyze and manage our Services for user services, security, fraud-detection,
  • 3.1.4 to improve our Services and respond to your desires and preferences,
  • 3.1.5 to develop new services or products and improve user experience,
  • 3.1.6 to check the authenticity of an account owner,
  • 3.1.7 to communicate with users (including push notifications to keep users up to date with the latest information relating to our Services),
  • 3.1.8 to verify and confirm payment,
  • 3.1.9 to perform our contractual obligations towards you with respect to our Services,
  • 3.1.10 to perform necessary tasks for us in relation to the Services,
  • 3.1.11 to exercise or defend legal claims,
  • 3.1.12 to fulfill our obligations under applicable laws and regulations, respond to requests of government authorities,
  • 3.1.13 for any other purposes for which we provide specific notice at the time the data is collected.
• 3.2 If you give us your consent, we also use your personal data including activity log in order to analyze your use of the Services and deliver targeted advertising content to you on this application and on other websites across the Internet. You may opt-out your consent through “Allow Personalized Ads” settings in Menu by turning off the "allow".
• 3.3 We collect your personal data directly from you (including in cases where personal data is obtained automatically). However, we may obtain your personal data indirectly from third parties, including website traffic analysis service providers, such as Google LLC (who provide Cookies, IP addresses, provider information, terminal information, web browser information, user activities, attributes). We may infer your personal data by means including automatic means.
• 3.4 We process your personal data in accordance with the legal bases prescribed in applicable data protection regulations (such as the consent of the data subject, performing contractual obligations, legitimate interests, and compliance with laws and regulations).

4. Who we share personal data with

• 4.1 We may disclose or provide your personal data to third-party service providers we engage to help us operate the Services or respond to your inquiries, KOEI TECMO QUALITY ASSURANCE CO., LTD. (for customer service support).
• 4.2 If you give us your consent to using your personal data including activity log for marketing purpose, we disclose such data to third-party advertising agencies we have partnership with. You may opt-out your consent through “Allow Personalized Ads” settings in Menu by turning off the "allow".
• 4.3 We may also share your personal data with external auditors, law enforcement agencies and/or regulatory bodies to comply with our statutory obligations.
• 4.4 We may share your personal data with any other third party upon your consent.
• 4.5 We may share your personal data that is otherwise permitted by applicable data protection regulations.

5. How we ensure data security

• 5.1 We have put in place appropriate security measures to protect your personal data against accidental loss, unauthorized access, alteration, or disclosure.
• 5.2 We control our service providers by contractual arrangement that ensure that they process your personal data solely on our instructions, that they are subject to confidentiality obligation, and that they put in place appropriate security measures under our instruction.

6. How long we keep personal data

• 6.1 We will keep your personal data, as a general rule, as long as your account is active or only for as needed to provide you the Services unless deleted in accordance with your request or as otherwise required by law.
• 6.2 Thereafter, we will keep your personal data for as long as is necessary:
  • 6.2.1 to respond to any requests, questions, complaints, claims or other communication made by you or on your behalf,
  • 6.2.2 to show that we treated you fairly, and
  • 6.2.3 to keep records required by law.
• 6.3 Thereafter, we will not retain your personal data for longer than necessary for the purposes set out in this notice. When it is no longer necessary to retain your personal data, we will delete or blocked or anonymized it.

7. Third-country data transfer

For the purpose described in Section 3 above, we may transfer personal data to foreign countries and regions outside of your residence including Japan, and we will take appropriate protection measures to transfer personal data.

8. Your legal rights with personal data

• 8.1 We respect the rights you hold under the applicable data protection laws and regulations of each country and region. For example, as far as the applicable data protection laws and regulations of each country and region grant, you may have right to access; right to rectification; right to erasure; right to restriction of processing; right to objection to processing; right to withdraw your consent (it may be granted if you have given your consent regarding certain types of processing activities; however, your withdrawal of consent does not affect the lawfulness of processing conducted based on your consent before its withdrawal.); right to data portability; and right to not be subject to automated decision-making and so on. Act on the Protection of Personal Information of Japan grants the right to request the following in relation to retained personal data (meaning retained personal data prescribed in Article 16, paragraph 4 of the Japan’s Act on the Protection of Personal Information): 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 third-party provision prescribed in Article 37, paragraph 2 of the Japan’s Act on the Protection of Personal Information).If you wish to exercise your right, please contact us. We may request for authentication of your identity that is reasonable considering the nature of the personal data requested. If you would like to designate an authorized agent to make a request on your behalf, you must provide your valid power of attorney to us. We may require further authentication of you or the agent, if deemed necessary.
• 8.2 In many circumstances, we need to use your personal data for us to provide you with our Services of your choice. If you do not provide us with the required personal data, or if you withdraw your consent to our use and/or disclosure of your personal data for these purposes, it may not be possible for us to continue to serve you or provide you with the services that you require.

9. Protection of Children’s Privacy

Our Services are not marketed to, or intended for those who under the age of 16 years old. We may collect age information before allowing a user to proceed for certain services and if we discover that we have inadvertently collected personal data from children under the age of 16, we will take all reasonable measures to delete any records of such personal data that come to our attention.

10. COMPLAINT

You can lodge complaints if you are not satisfied with our way of processing your personal data with data protection supervisory authority.

11. Contact us

• For further information and inquiry, contact:
  Privacy Policy Contact
  KOEI TECMO HOLDINGS CO., LTD.
  1-18-12 Minowa-cho, Kouhoku-ku,
  Yokohama, 223-8503, Japan
  e-mail：privacy@koeitecmo.co.jp
  

Effective January 7, 2025

Exhibit: EEA (European Economic Area) and UK

Effective date: [2024/01/25]

Last updated: [2024/01/23]

This Exhibit (a) applies to the processing of your personal data by Koei Tecmo if you are located or residing in the EEA (European Economic Area) or the UK and refers to the GDPR and the UK GDPR (collectively, the “GDPR”).
This Exhibit includes information about your data protection rights, including a 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 “3. Your rights” below.

1. Legal basis for processing

We process your personal data pursuant to the following legal basis for the purposes stated in 3.1 and 3.2 of this Privacy Policy.

| When processing is necessary for the performance of a contract (GDPR Article 6, Paragraph 1, Item (b))

• - to provide you the Services of your choice;
• - to check the authenticity of an account owner;
• - to verify and confirm payment; or
• - to perform our contractual obligations towards you with respect to our Services.

| When processing is necessary for pursuit of legitimate interests (GDPR Article 6, Paragraph 1, Item (f))*

• - to deliver non-personalized advertising content relevant to the Services;
• - to analyze and manage our Services for user services, security, fraud-detection,
• - to improve our Services and respond to your desires and preferences;
• - to develop new services or products and improve user experience;
• - to communicate with users (including push notifications to keep users up to date with the latest information relating to our Services);
• - to perform necessary tasks for us in relation to the Services;
• - to exercise or defend legal claims; or
• - to fulfill our obligations under applicable laws and regulations of countries other than countries in the EEA and the UK and respond to requests of government authorities.

*For details of the balancing test for legitimate interests (GDPR Article 6, Paragraph 1, Item (f)), please contact us using the contact details stated in “4. Contact details of representatives and data protection officers” below.

| When processing is necessary for compliance with a legal obligation (GDPR Art. 6(1)(c))

• - to fulfil our obligations under applicable laws and regulations of the EEA and the UK.

| When we obtain consent to the processing from customers in advance (GDPR Article 6, Paragraph 1, Item (a))

• - For using your personal data including activity log in order to analyze your use of the Services and deliver targeted advertising content to you on this application and on other websites across the Internet; or
• - For the processing of not strictly necessary cookies.

2. Overseas transfer of personal data

If we transfer personal data to areas other than the EEA (European Economic Area) or the UK, we (i) will be based on an adequacy decision (GDPR Article 45) in the countries where the adequacy decision is adopted or (ii) will take appropriate protection measures by executing the standard data protection clauses approved by the European Commission (GDPR Article 46, Paragraph 2, Item (c) and Paragraph 5) or the standard data protection clauses approved by ICO (UK GDPR Article 46, Paragraph 2, Item (d)) with the party receiving personal data in the countries where an adequacy decision is not adopted.

Please click here with respect to the details of the adequacy decision to Japan.

Please contact us using the contact information stated in 11 of the Privacy Policy if you wish to receive a copy of the documents relating to those protection measures.

3. Your rights

You have the following rights.

• - Obtaining information regarding data processing: You have the right to obtain from us all necessary information regarding our processing of data concerning you (GDPR Article 13 and Article 14).
• - Access to personal data: You have the right to obtain confirmation from us as to whether personal data concerning you is being processed, and, where that is the case, to access the personal data and certain relevant information (GDPR Article 15).
• - Rectification and erasure of personal data: You have the right to have us rectify inaccurate personal data concerning you without undue delay and have incomplete personal data completed by us (GDPR Article 16). You also have the right to have us erase personal data concerning you without undue delay when certain conditions are met (GDPR Article 17).
• - Restricting processing of personal data: You have the right to restrict our processing of personal data concerning you when certain conditions are met (GDPR Article 18).
• - Objection to processing of personal data: You have the right to object to our processing of personal data concerning you when certain conditions are met (GDPR Article 21, Paragraph 1).
• - Objection to direct marketing: You have the right to object at any time to our processing of personal data for direct marketing (GDPR Article 21, Paragraph 2).
• - Data portability: You have the right to receive personal data concerning you in a structured, commonly used, and machine-readable format and to transmit that data to another controller without hindrance from us, when certain conditions are met (GDPR Article 20).
• - Right to withdraw your consent: You have the right to withdraw your consent at any time by the means separately specified at the time we obtain your consent. However, your withdrawal of consent does not affect the lawfulness of processing conducted based on your consent before the withdrawal.
• - Freedom from automated decision-making: When certain conditions are met, you have the right not to be subject to automated (meaning without human involvement) decision-making that produces legal effects or significant effects on you (GDPR Article 22).
• - Regarding our processing of your personal data, you may lodge a complaint with the relevant data protection supervisory authority of the member state where your habitual residence, your place of work, or the place of the alleged infringement, is located (GDPR Article 77).

4. Contact details of representatives and data protection officers

The contact details of representatives in the UK as well as our Data Protection Officer are as follows.

• - Representative in the UK

    Full name of company: Koei Tecmo Europe Ltd.
    Name or title of data privacy manager: General Manager
    Email address: privacy@koeitecmo.co.uk
    Postal address: Unit 403a, The Spirella Building, Bridge Road, Letchworth Garden City, Hertfordshire, SG6 4ET
    Telephone number: +44(0) 1462 476130
  

• - Data protection officer

    Full name of company: Koei Tecmo Games Co., Ltd.
    Name or title of data privacy manager: Koinuma Hisashi
    Email address: privacy@koeitecmo.co.jp
    Postal address: 1-18-12 Minowa-cho, Kouhoku-ku, Yokohama, 223-8503, Japan
  

Exhibit: U.S.

Effective date: [2024/01/25]

Last updated: [2024/01/23]

This Exhibit (a) applies to the processing of your personal data by Koei Tecmo if you are located or residing in the U.S..

This Exhibit includes information about your data protection rights, including a 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 below.

1. You have the legal rights to request from us the following:

• - information on what personal data we have about you and access to your personal data and other supplementary information.
• - having your personal data rectified.
• - having your personal data erased.
• - having our processing of your personal data frozen.
• - obtaining your personal data in a structured, commonly used and machine-readable format.
• - not being subject to automated decision making and profiling.
• - to opt-out personal data including activity log through “Allow Personalized Ads” settings in Menu by turning off the "allow".
• - to request certain information regarding its disclosure of personal data to third parties for direct marketing purposes pursuant to Section 1798.83 of the California Civil Code via email described in Section11 with “California Shine the Light Request” in the subject line.

2. If you are a natural person who is a California resident refers to the California Consumer Privacy Act (the “CCPA”), even if you are temporarily outside of California State, you also have the following rights:

• - to know what categories and specific pieces of personal data are collected about you. As such, you may submit a verifiable consumer request via email described in Section11 with “CCPA Information Collected” in the subject line.
• - to know what personal data is used, sold, shared, or disclosed with third parties and to whom. You may submit a verifiable consumer request via email described in Section11 with “CCPA Information Shared” in the subject line.
• - to opt-out of the sale or share sharing of your personal data by us to third parties at any time. You can submit a request to opt-out by submitting a verifiable consumer request via email described in Section11 with “Do Not Sell or Share” in the subject line.
• - subject to statutory exclusions, to request that we delete the personal data and correct inaccurate personal data that we have collected about you. You may submit a verifiable consumer request via email described in Section11 with “CCPA Information Deletion” in the subject line.
• - to limit the use and disclosure of sensitive personal data that we have collected about you. You may submit a verifiable consumer request via email described in Section11 with “CCPA Information Limitation” in the subject line.

3. If you wish to exercise your right, please contact us via email described in Section11. We may request for authentication of your identity that is reasonable considering the nature of the personal information requested. If you would like to designate an authorized agent to make a request under the CCPA on your behalf, you must provide your valid power of attorney to us. We may require further authentication of you or the agent, if deemed necessary.