Preface

Aiming Inc. (hereinafter referred to as “we”, “us” or “our”) adheres to the relevant personal information protection laws and regulations to ensure appropriate handling of information concerning users.
This Privacy Policy applies to users residing in the United States and shall be in accordance with the Act on the Protection of Personal Information of Japan (Act No.57 of 2003, including its subsequent amendments, hereinafter referred to as the “Personal Information Protection Act”), as well as any relevant Federal or State laws. Please confirm each item for any special regulations for each State.
Except where otherwise specified, the definition of “personal information” and other terms in this Privacy Policy shall be in accordance with those in the Personal Information Protection Act.
Please print or screen capture this Privacy Policy for record-keeping purposes as necessary.
Users who are visually impaired can access an alternative version of this information using a screen reader. Users with other impairments can reach out to us using the contact information found below in section “13. Contact” and learn about other accessibility options to assist in accessing this Privacy Policy.
Our services may contain links to other websites or services. As this Privacy Policy applies exclusively to our services, please confirm the Privacy Policy for that website when using links to other websites.
When making changes to the Privacy Policy, we will notify users by posting on our website, sending an email, or by any other method that we deem appropriate (in accordance with any method required by laws and regulations). We will also adhere to any further processes required by privacy policy regulations.
Except for cases in which we stipulate otherwise, the revised Privacy Policy shall take effect from the time it is posted on this website.
Users are encouraged to visit this page regularly to confirm any possible updates. Users can confirm when the Privacy Policy was last updated by checking the “Last Updated” date.
The Privacy Policy for the United States shall apply to users residing in the US.

1. Concerning the Information We Collect

Personal information refers to any information concerning a specific or identifiable natural person that is processed by us.
We collect data via the device used by the user to interact with us, and through third parties. We may combine data from our services with other data collected from our business records. We may use or share aggregated data (compile statistics where individual records cannot be identified from the data) or anonymized data (remove personal identifiers so that data cannot be linked to a specific individual).
There may be cases where a user’s personal information may need to be provided for statutory reasons, contractual reasons, or a requirement to enter a contract.
In such a case, we may be unable to provide our services to the user if they are unable to provide personal information.
As an example, the provision of information associated with a user’s registration for our service is a requirement for using the service. Additionally, the provision of the user’s device information is a requirement for the user to use our websites.

■ Information Relating to Registering for Services

Upon registering for our services, users may be asked to provide the following information:

1. (1) A name identifying the user (e.g., full name, user name, nickname, etc.)
2. (2) Email address
3. (3) Date of birth
4. (4) Gender
5. (5) Other information about the user that we specify
6. (6) In the case of a minor (under 16 years of age), additional information regarding their legal representative (full name, date of birth, email address, phone number)

■ Device Information

The following information may be collected when using our services and websites:

1. (1) Cookies and other device identifiers
2. (2) IP addresses
3. (3) Device type and model
4. (4) OS and version number
5. (5) Other information that the user has agreed to provide

■ Location Data

In order to provide services that require location information, we may collect location data from the user’s device.

■ Payment Information

In order for users to purchase virtual currency or licenses to use virtual items offered via our services, we may collect the following billing and payment information provided to third-party payment service providers (including, but not limited to, Apple Inc. and Google LLC):

1. (1) Purchase ID, purchase date, purchased product, or purchase history details such as amount spent
2. (2) Postal/Zip code

■ Information Related to Customer Support

We may collect and store the following information when providing customer support to users:

1. (1) Contact information (typically, but not limited to, an email address)
2. (2) Device model, OS information, information regarding the use of our services
3. (3) User ID
4. (4) Correspondence with support and any information contained therein

■ Information Related to the Use of Our Services

When users use our services, we may collect and store the following information provided directly to us by them, as well as other data pertaining to how they use our services.
We may also record and store interactions between users on our services and any information contained therein.

1. (1) Device identification data, operating system, hardware version, device setup, browser type and setup, and data regarding website and application usage
2. (2) IP addresses, log data, usage time, Cookies, and web beacons
3. (3) Emails and text-based messages, gameplay content, support inquiry history, search terms entered by the user, chat history and other interactions between users, and performance data

■ Information Regarding User Interests and Preferences

Subject to the user’s consent, we may collect information regarding the interests and preferences of users inferred from their browsing and purchase history.

■ Information Gathered Using Cookies etc.

When a user accesses our services or websites, we may use Cookies or similar technologies to obtain data regarding their usage environment (browser, etc.), services, and website usage. We may also use similar technologies in some of our advertising systems.

■ Cookie Settings

We may collect and use the following Cookies or similar technologies in various ways to improve the user experience of our services.

1. (1) Essential Cookies
   These Cookies are necessary for our services to function properly and include Cookies necessary to create an account. These Cookies are not used to collect information for marketing purposes nor do they store websites visited by the user.
2. (2) Performance Cookies
   Collect information about how users use our services, including information about the pages they visit most frequently. If a user has previously specified certain preferences, those preferences will be stored in these Cookies. We use these Cookies to improve our services and to optimize the user’s experience so that they can search for our services more conveniently.
3. (3) Functionality Cookies
   Used to store settings such as layout, text size, basic settings, language, etc. in order for us to provide our services and improve user experience. Information collected by these Cookies is not used to identify individual users.

Users are able to disable Cookies through their browser settings, but this may cause some of our services and third-party services to not function properly.

We use the following access analysis tools on our services and websites. These analytics tools use Cookies in order to collect data. The data is collected anonymously and cannot be used to identify individuals. It is possible for users to disable Cookies and prevent these tools from collecting their data. Please check your browser settings for more details.

1. (1) Google Analytics
   Google Analytics uses Cookies and other means to collect user information. To learn more about how Google Analytics collects and utilizes information when users visit our websites, please visit the “How Google uses information from sites or apps that use our services” page.
   http://www.google.com/policies/privacy/partners/
   For more information on the terms and conditions regarding Google Analytics, please refer to the Google Analytics Terms of Service and Google’s Privacy & Terms.
   https://marketingplatform.google.com/about/analytics/terms/us/
   https://policies.google.com/technologies/ads
2. (2) Google Analytics Opt-out Add-on
   Users can also disable Google Analytics via their browser’s add-on settings to stop the collection of their information due to our use of Google Analytics. To disable Google Analytics, download and install the Google Analytics Opt-out Add-on from the Google Opt-out Add-on download page and change the add-on settings of your browser.
   https://tools.google.com/dlpage/gaoptout
   For the terms and conditions of the Google Analytics Opt-out Add-on, please see “Google Analytics Opt-out Browser Add-on – Additional Terms of Service” and Google’s Web Store Terms of Service.
   https://tools.google.com/dlpage/gaoptout/intl/en/eula_text.html
   https://policies.google.com/terms
3. (3) Microsoft Clarity
   For more information on Microsoft Clarity’s terms and conditions, please see the Microsoft Privacy Statement.
   https://privacy.microsoft.com/en-us/privacystatement

■ Information Regarding the Usage of Services

We may acquire the IDs of external services used by users and other information that users have authorized our partners to disclose to us as per the privacy settings of those external services.

1. (1) User ID of external service provider
2. (2) Other information that the user has authorized to disclose to related companies

2. Purpose of Use of Collected Information

We process collected personal information to achieve the following objectives.
Additionally, where required by law, we will only conduct direct marketing to customers after obtaining their consent.

3. Retention Period of Personal Information

To determine the appropriate retention period for personal information, we consider the volume, nature, and sensitivity of the personal information, the risk of potential damage from its unauthorized use or disclosure, the purposes for which we process it, and whether or not we can achieve those purposes by other means, along with any applicable legal requirements. When our company no longer requires the personal information of users that we have collected, we will delete or anonymize the information. If deletion is not possible (for example, if the personal information is stored in backup archives) we will securely store the user’s personal information until it becomes possible to delete and will ensure that no further processing of the personal information takes place thereafter.

4. Safety Management of Collected Information

We will take necessary and appropriate measures to prevent the leaking, loss, or damage of any personal information that we handle, and otherwise safely manage such information.
Please note that while we have taken these precautions to protect user information, this does not ensure the safety of the networks, systems, servers, devices and databases that we operate, or on our behalf.

5. Source for Obtaining Personal Information

We acquire the personal information of users directly, either by receiving it from them or by obtaining it automatically. However, for personal information of users who access our website, the information is indirectly acquired from external services usage analysis services used by our websites, such as Google LLC, Adjust Inc., AppsFlyer Ltd., payment service companies such as Apple Inc. and Google LLC, application development companies such as Sauce Labs Inc., as well as external services used by users.

6. Sharing and Providing Acquired Information to Third Parties

In order to achieve the purposes described in “2. Purpose of Use of Collected Information” above, our company may share the personal information described in “1. Concerning the Information We Collect” above with the following third parties:

■ Affiliated Companies

We share information with members of our company group.

■ Processors (Service Providers)

We may hire vendors to perform certain business functions on our behalf, and these vendors may receive or directly collect information about users from us. Vendors and the business functions they provide may include the following:

1. (1) Businesses, such as Sauce Labs Inc., that provide service support functions such as customer service, customer relationship management, application development, list cleansing, physical mailing, and communications (email, fax).
2. (2) Auditing and accounting firms, such as those that assist in the preparation of our financial records.
3. (3) Specialized service consultants, such as companies that conduct analysis, provide support to improve our business, provide legal services, or provide project-based resources and support, etc.
4. (4) Providers of analysis and marketing services, such as Google LLC and AppsFlyer Ltd. (including companies who analyze the traffic of our online assets, identify potential customers, and assist with communications).
5. (5) Security vendors (such as those supporting the identification of and response to security incidents, service notifications, and fraud prevention).
6. (6) IT vendors (such as those supporting website design, hosting and maintenance, data and software storage, and network operations).
7. (7) Marketing vendors (such as those supporting the delivery of marketing emails).
8. (8) Other service providers necessary for our business activities.

■ Business Partners for Marketing Purposes

We may share a user’s device identifiers and information about their use of the services with our marketing business partners for marketing purposes.

■ Online Advertising Partners

We work with companies who assist us with advertising our services using tools such as Cookies and online tracking technologies to collect information and measure the effectiveness of personalization, retargeting, and advertising.

■ Social Media Platforms

If a user interacts with us on a social media platform, that platform may be able to collect information about the user and their interactions with us. When a user interacts with social media objects (such as clicking the “Like” button on Facebook), both the platform itself and the user’s connections on said platform may be able to see that activity. To manage how such information is shared, please review the privacy policy of the social media platform in question.

■ Government Institutions and Law Enforcement Agencies

We may share information when we believe in good faith that we are lawfully authorized or required to do so in order to respond to a legal subpoena, warrant, court order, or other regulatory or law enforcement requests, or when necessary to protect our property or rights or the safety of our employees, customers, or other individuals.

■ Other Businesses Involved in Commercial Transactions

Our company’s ownership or corporate structure may change during the course of providing our services. We may transfer some or all of the information concerning our users to other entities, their affiliates, or service providers connected to them, or during negotiations relating to a merger, acquisition, sale of assets or lines of business, change in ownership, or financing transactions. We cannot guarantee that an acquired or merged entity will have the same privacy practices or treat user information as described in this policy.

7. Sending Personal information to third parties

We use services from the third parties described below in the provision of our services.
Such third-party services require certain user-related information in order to function. In particular, Cookies and similar technologies must be used to transmit information about users from their devices to servers owned by third-party service providers.
Among the external services we currently use for external transmission, matters to be disclosed based on the provisions of the Telecommunications Business Act regarding external transmission discipline are as follows.
For details regarding how third-party service providers use user-related information, please refer to the links provided in “Privacy policies, etc.”

8. Transfer of Personal Information Overseas

We may collect, process, and store your information in the United States and in other countries such as Japan. Information laws in the United States may differ from those of the country in which the user resides. Any such transfers of data will be conducted using the required protective measures in accordance with the relevant laws.
Please follow the below link for more information regarding the system in place for the protection of personal information in the US, to which personal information must be provided to under Japan’s Personal Information Protection Law. Third parties located in foreign countries to whom we provide personal information ensure appropriate protection of personal information, such as by complying with the laws and regulations regarding the protection of personal information within their country.
【United States (Federal Law)】
https://www.ppc.go.jp/files/pdf/USA_report.pdf

9. A User’s Rights to Information

■ User Accounts

Users can update their account information from the account page of the application.

■ Advertising Options

Users have the option to limit the information we and our partners collect for online advertising purposes.

1. (1) Users may disable Cookies via the settings menu of their browser or mobile device. Mobile devices may offer the option to disable advertising features. Because we use Cookies to facilitate the functionality of our services, disabling Cookies may also disable certain elements of our online assets.
2. (2) Users may also contact us about this directly.
Please note that if a user chooses to make use of these options, they may still see advertisements, but they will not be personalized. Moreover, using these options will not prevent other companies from delivering personalized advertisements to users. Deleting Cookies may also erase your opt-out settings.

■ Concerning Do Not Track

In some cases, a user’s device may contain a “Do Not Track” feature. Our data collection, disclosure practices, and the choices we offer users will remain as described in this Privacy Policy, regardless of whether or not we receive a Do Not Track signal.

■ Rights in Specific Jurisdictions

Users may have certain rights with respect to their personal information depending on their location or place of residence. Please see “11. Privacy Disclosures for Specified Jurisdictions” below. If you wish to exercise any of these rights, please contact us using the email address provided in “13. Contact”.

10. Protection of Children’s Personal Information

When the legal basis for the processing of personal information is the user’s consent, we do not intentionally collect personal information from individuals under the age of 16 without prior consent from a parent or legal guardian. For children under the age of 16 who wish to use our services, please receive consent from their legal representative.
We may grant the child’s legal representative the right to review the child’s personal information, the right to edit, delete or temporarily suspend the child’s personal information, as well as withdraw the before mentioned consent.

11. Privacy Disclosures in Specified Jurisdictions

■ Privacy Rights Law for Residents of California

1. (1) California “Shine the Light” Privacy Rights Law
   Once per year, free of charge, residents of California may request a list of the categories of personal information that we have disclosed to third parties for direct marketing purposes, as well as the names and addresses of such third parties, in cases in which we have made such disclosures for the purposes of direct marketing in the previous calendar year. Additionally, users may request that we not share their personal information with third parties for marketing purposes. Please contact the email address under “13. Contact”. if you wish to obtain this information.
2. (2) Notice to California Residents Under the Age of 18
   Users under the age of 18 may request that we delete any information or content they have posted on our online services. Please note, however, that we are unable to delete any information that was collected, stored, or shared by a third party at the time the user posted such content or information. To request the deletion of user information, Please contact the email address under “13. Contact”
3. (3) California Consumer Privacy Act
   The California Consumer Privacy Act (CCPA) provides residents of California the right to receive certain disclosures regarding the collection, use, and disclosure of information about them, as well as the right to know, delete, correct, and opt out of the sale or sharing of their personal information. Users have the right to non-discrimination for exercising their rights under the CCPA. To the extent that we collect personal information subject to the CCPA, that information, our practices, and the rights of users are described below. These details are intended for users covered by the CCPA and apply to personal information as defined by the CCPA. Although this Privacy Policy applies to users covered by the CCPA, in the event of any conflicts between the following statements regarding the CCPA and other statements in this Privacy Policy, the statements regarding the CCPA shall take precedence.
4. (4) Categories of Personal Information Collected
   We collect personal information as it is defined by the CCPA. We have specifically collected the following categories of personal information in the past 12 months:
   
   • (a) Identifiers (names identifying users, email addresses, online identifiers, IP addresses, etc.)
   • (b) Categories of personal information (e.g., name, phone number, etc.) as described in the California customer records statute (California Civil Code Section 1798.80(e))
   • (c) Information regarding activities on the internet or other electronic networks (e.g., information on the use of services as described in “1. Concerning the Information We Collect” listed above)
   • (d) Commercial information (e.g., purchase history and information related to customer support as described in “1. Concerning the Information We Collect” listed above)
   • (e) Location data
   • (f) Inferences derived from the information we collect, such as consumer preferences and disposition (e.g., user interests and preferences inferred from browsing and purchase history)
     For a list of the personal information that we collect from users, please see “1. Concerning the Information We Collect” above.
5. (5) Categories of Sources of Personal Information
   Additionally, during the past 12 months, we have acquired personal information as described above in (3) from the sources listed in “5. Sources of Personal Information.”
6. (6) Business or Commercial Purposes of Personal Information
   As described in “2. Purpose of Use of Collected Information,” we use personal information for business and commercial purposes.
7. (7) Categories of Personal Information Recipients
   In the past 12 months, we have shared user identifiers, information about user activities on the internet or other electronic networks, commercial information, and inferences we have derived about our users with our marketing business partners, online advertising partners, and social media platforms.
   According to the CCPA, there may be cases in which this may be considered the sale of personal information for compensation and/or the “sharing” of personal information for cross-context behavioral advertising.
   We will not disclose the personal information of users known to be under the age of 16 to other companies or third parties for compensation or cross-context behavioral advertising.
   We have disclosed all or substantially all of the personal information from the categories identified in “1. Concerning the Information We Collect” above to our affiliates, service providers, and others, as specified in “6. Sharing and Providing Acquired Information to Third Parties” above.
8. (8) User Rights Based on CCPA
   Users have certain rights regarding the user’s personal information. Excluding certain exceptions and limitations, users may exercise the following rights with regard to their personal information. Please contact the email address under “13. Contact” if you wish to exercise these rights.
   
   • (a) Opting Out of the Sale or Sharing of Personal Information
     Users have the right to opt out of having their personal information sold or shared with third parties by us. To exercise this right, please make a request to not sell personal information by contacting us at the email address under “13. Contact”.　Please note that a user’s right to opt out does not apply to the disclosure of personal information to our service providers.
     We will also process opt-out requests submitted via a user’s opt-out preference signals as required by any applicable laws. The technical specifications of a user’s opt-out preference signal will determine how we process that signal. For example, if a consumer installs opt-out preference technologies in a browser and the opt-out preference signal it sends is associated only with the user’s browser, the opt-out will apply to that browser. As of the “Last Updated” date of this Privacy Policy, our processing of opt-out preference signals can be considered “frictionless” under California law.
     Instructions on setting up and using opt-out preference signals can be found by visiting the California Attorney General’s CCPA page, in the section relating to “requesting personal information not be sold (right to refuse sale).” Information on how to set up and use opt-out preference signals is also available from the California Privacy Protection Agency (CPPA).
   • (b) Sensitive Personal Information
     We will not use or disclose sensitive personal information for any purpose that would require us to offer users the “right to limit” the use or disclosure of their sensitive personal information.
   • (c) The Right to Know Personal Information
     Users have the right to know what categories and/or specific pieces of personal information of theirs we have collected, used, disclosed, or sold; the categories of sources of personal information we have collected about them; our purposes for collecting or selling personal information about them; the categories of personal information about them that we have sold or disclosed for business or commercial purposes; and the categories of third parties with whom we have shared their personal information.
   • (d) The Right to Request the Deletion of Personal Information
     In certain circumstances, users have the right to request that we delete personal information that we have collected directly from them. Please note that if a user requests that we delete their personal information for a service that requires the use of said personal information, we may no longer be able to provide them with said service.
   • (e) The Right to Request the Correction of Personal Information
     Users have the right to request that we correct any inaccurate personal information that we have about them.
   • (f) The Right to Non-Discrimination
     We cannot discriminate against a user on the basis of the user exercising the aforementioned privacy rights or any other rights under the CCPA.
9. (9) Financial Incentive
   From time to time, we may offer our users the opportunity to participate in special promotions or programs, such as Twitter Instant Wins, and the programs we offer may qualify as financial incentive programs (FIPs) under California law.
   We will use the personal information that users provide us to allow participation in drawings for chances to win in-game currency. User participation is voluntary. The categories of personal information that we will collect are social media and game account information. We will use this information to facilitate user participation in such programs. If we run such a program in collaboration with a business partner, we may disclose information to that business partner.
   Users will be able to opt in to Instant Wins using the means we present to them at the time we make such offers, such as through online registration pages, etc. Users can withdraw from Instant Wins at any time using the means we provide to them.

■ Privacy Rights Law for Residents of Nebraska, Texas and Nevada

1. (1) User Rights
   Except in exceptional cases, the user may have the following rights:
   
   • (a) The Right to Access
     Users have the right to access their personal information, as well as confirm how we process a user’s personal information.
   • (b) The Right to Correct
     Users have the right to request to make corrections to any incorrect personal information that we may have.
   • (c) The Right to Remove
     In specific circumstances, users have the right to request to have their personal information removed.
   • (d) The Right to Opt-Out
     Users have the right to refuse or opt-out of the following processes.
     ・Target advertising
     ・Selling personal information
     ・Certain types of profiling and automated decision-making
   • (e) The Right to Data Portability
     Users have the right to request a copy of their personal information in a format that is accessible to them.
   • (f) The Right to Receive Equal Services
     We will not discriminate against any users who wish to exercise any of the said rights. Please note that in the case of using certain rights, users may not be able to use or access certain features of our websites, services or properties.
   • (g) The Right to Appeal
     Users have the right to appeal to a rejection in the event that our company does not approve of the customer’s consumer billing.
     As mentioned below in “(2) Submission of Requests Regarding Privacy Rights”, users have the right to exercise authority over these privacy rights.
2. (2) Submission of Requests Regarding Privacy Rights
   When exercising rights related to data privacy, please confirm “12. Request to Exercise Rights”. There is no need to create an account with us when making a request. In accordance with the applicable law, there are cases where there may be a limit to the number of times certain requests can be made in the duration of 12 months.

12. Requesting to Exercise Rights

■ Submitting a Request

Users can contact the email address under “13. Contact” to send a request to exercise their rights.
In the event that users, under the applicable laws and regulations, are permitted to allow another person or company (i.e. an authorized agent) to exercise rights in their stead, the request to use such rights can be made through the authorized agent, who is legally appointed under such law.
There are cases where we have legal reasons for not complying with the user’s request or complying with the user’s request in a more limited method that the user is expecting. In such a case, we will explain our reasons in our response.

■ Verification

We will first need to verify the identity of the user before responding to a user’s request. In order to confirm the identity, we will request for personal identifiers, which we will match with personal information that we may have collected from the user previously. We may need to follow up on the user to request further information verify the identity of the user. We will not use personal information collected while verifying or fulfilling the user’s request, for any other purpose than responding to the request.

13. Contact

If you have any questions, comments, feedback, or inquiries regarding the handling of the personal information of users, please contact us using the contact form below.

Contact Form