PRIVACY POLICY
Akatsuki Taiwan Inc. (hereinafter referred to as the “Company”) is committed to protecting user personal data and privacy. The Company sets forth this Privacy Policy regarding the collection, processing, and use of personal data involved when you use the Company’s websites, games, mobile applications, other online products, or any other services provided by the Company (hereinafter collectively referred to as the “Services”), or when you otherwise contact or interact with the Company. You should carefully read this Privacy Policy before you start using the Services. By using the Services, you signify your agreement to this Privacy Policy as follows:
1. Purpose of Data Collection
(1) The Company will collect personal data pursuant to this Privacy Policy. The user personal data (as defined in Article 2) obtained through the provision of the Services will be used by the Company within the scope of the following purposes in accordance with relevant laws and regulations:
a. To provide, maintain, and improve the Services, to personalize the Company’s services, and to provide advertising, content, features, messages, and marketing
b. To provide and deliver the products and services you request, process transactions, and send you related materials;
c. To register your account within the Services and assist in managing your account;
d. To respond to your comments, questions, and requests, and to provide customer service;
e. To send you technical notices, updates, security alerts, support, and administrative messages;
f. To contact you regarding products, services, offers, promotions, rewards, events, and other information related to the Services provided by the Company;
g. To monitor and analyze trends, usage, and activities related to the Services;
h. To process contest applications, award prizes, and handle various game-related events promoted by the Company;
i. To contact you or provide job-related information for the processing of the Company’s personnel and employment matters;
j. To optimize the services by linking or combining with data legally obtained by the Company from third parties;
k. To detect, investigate, and/or prevent fraudulent acts, unauthorized, or illegal activities;
l. To be processed by the Company or used by a third party making a request to the Company, or an authorized third party, to comply with legal and regulatory obligations;
m. For any other purpose for which you provided the information.
(2) In principle, the Company will only use the information you provide within the scope of the above purposes; however, nothing in this Privacy Policy shall limit or restrict the Company from using your personal data outside the scope of the above purposes, provided that such use complies with relevant laws and regulations.
(3) You may choose whether or not to provide your personal data. However, if you refuse to provide the personal data necessary for the Services, it may result in you being unable to enjoy complete services or being completely unable to use the Services.
2. Content of Collected Data
The Company will collect the following personal data in accordance with this Privacy Policy. However, except as otherwise permitted or prescribed by law, the Company will not attempt to collect, process, or use special categories of personal data (sensitive personal data) such as medical records, medical treatments, genetic information, sex life, health examinations, and criminal records:
(1) Personal data you directly provide to the Company, including:
The Company collects personal data you directly provide to us, such as when you create or register an account, make purchases within the Services, interact with other users, upload images and other information to the Company’s servers, request customer service, subscribe to and receive newsletters, participate in surveys, apply for employment with the Company, or otherwise contact us. In such instances, the personal data collected by the Company includes your name, username, password, email address, profile photos, and any other personal data you choose to provide.
(2) Personal data automatically collected by the Company when you access or use the Services, including:
a. Usage data: The Company collects personal data regarding your use of the Services, including game service identifiers, game levels achieved, game scores, duration of service usage, and other personal data related to your game participation.
b. Log data: The Company records personal data regarding your use of the Services, including your browser type, version, language preferences, service access frequency, IP address, and the time spent and actions performed on the Company’s web pages.
c. Location data: Whenever you use the Services on iOS or Android platforms, or otherwise consent to the collection of location data, the Company may collect geographical location data from your device. You may change your device settings to opt out of location data collection. Prior to collection, such data may be temporarily stored for a period designated by the Services.
(3) Personal data collected by the Company from other lawful sources:
When providing the Services, the Company may also, where necessary and in accordance with applicable laws, collect personal data from other sources (including but not limited to the Company’s affiliates or business partners), and combine it with personal data collected through the Services. This includes, but is not limited to, collecting your game rankings and progression stage data from your console’s or mobile operating system’s game center applications. Furthermore, when you complete a purchase transaction through the application, the Company may collect personal data about you obtained by your device’s operating system provider while processing such transactions on behalf of the Company. However, the Company will not collect payment methods, credit card numbers, or financial account details from operating system providers.
3. Data Protection Measures
(1) The Company will implement technical and organizational measures in accordance with reasonable industry standards (including but not limited to restricting access to your personal data and deploying relevant security software) to safeguard all user personal data obtained under this Privacy Policy.
(2) The Company maintains a dedicated department for personal data protection to implement appropriate safeguards and continuously enhance its data management practices.
4. Period, Region, Recipients, and Methods of Data Use
(1) Period of Use:
a. The Company will process and use your personal data from the time you commence using the Services or otherwise contact or interact with the Company, and will continue to process, use, and retain your personal data for the period necessary to provide the Services and fulfill the purposes set forth in this Privacy Policy. This provision applies equally to the Company’s affiliates and business partners with whom the Company shares your personal data.
b. When the Company no longer needs to use your personal data, and its retention is no longer required to comply with legal obligations, the Company will delete it from its systems or anonymize it so that it can no longer be associated with you. When deleting personal data, the Company will adopt commercially reasonable and technically feasible measures to ensure that such deletion is irreversible and unrecoverable.
(2) Region of Use:
In addition to the regions where you and the Company are located, this includes the locations of the Company’s affiliates or business partners.
(3) Recipients of Data Use:
The Company, the Company’s affiliates, and its business partners, including:
a. The Company may entrust or transfer all or part of your personal data to third-party external service providers who process and use it on behalf of the Company (such as cloud storage providers). In such cases, the Company will enter into a confidentiality agreement with the contracted processor in advance pursuant to this Privacy Policy, and exercise necessary and reasonable supervision to ensure proper and secure data management.
b. The Company may share your personal data with third-party IT service providers supporting the Company’s websites, online services, and business systems; payment service providers processing your transactions; information security providers assisting in preventing abuse, fraud, tampering, or unauthorized use of the Services; and management consulting firms assisting with electronic communications between the Company and you.
c. The Company may share your personal data with third-party advertising partners (such as Google and Meta/Facebook) so that they can display products and services of interest to you across social media platforms, websites, or mobile games. For example, if you provide the Company with your email address, the Company may share it with Facebook to deliver customized advertisements to you.
d. To prevent crime or comply with legal obligations, the Company may share your personal data with law enforcement agencies to address fraudulent or criminal (or potentially fraudulent/criminal) activities. The Company may also disclose your personal data to police, regulatory bodies, or relevant government authorities in your jurisdiction or other regions upon receiving legally binding requests, orders, or as required by law.
(4) Method of Use:
Subject to applicable laws and regulations, the Company may process and use your personal data by automated or non-automated means (including but not limited to written and electronic methods).
5. Your Rights Regarding Personal Data
(1) With respect to your personal data, you may exercise the following rights:
a. Request access.
b. Request a copy.
c. Request supplementation or correction.
d. Request cessation of collection, processing, or use.
e. Request deletion.
(2) If you wish to exercise the above rights regarding your personal data, please submit your request in writing or via email using the contact information provided in this Privacy Policy. The Company will not charge you any fees for exercising these rights, but may charge reasonable administrative fees (such as photocopying costs) depending on the circumstances. To protect the personal data stored in the Company’s database, the Company may require you to provide information for identity verification when you exercise these rights.
6. Social Sharing Features
The Services may provide social sharing features or other integrated tools that allow you to share your activities or integrate the Services with social media platforms. These features enable you to share information with your friends or the public; however, you are responsible for configuring the relevant settings on the applicable social media platforms according to your preferences. For detailed information regarding the purposes of data collection, processing, and use by such social media platforms, please refer to the privacy policies of the respective platforms. Please note that the collection, processing, and use of personal data by social media platforms are beyond the scope of this Privacy Policy, and the Company shall not be responsible or liable for such practices.
7. International Transfer
Your personal data may be transferred to jurisdictions outside your country/region, including jurisdictions that do not provide the same level of data protection as your country/region. In such cases, the Company will implement appropriate safeguards to protect your personal data.
8. Third-Party Websites and Links
With respect to any third-party links, websites, or services that may be available on the Company’s website or through the Services, please note that such websites and services are not operated or controlled by the Company and are not covered by this Privacy Policy. Before accessing or using such websites or services, you are encouraged to review the terms of use and privacy policies provided by the relevant third-party providers. The Company shall not be responsible or liable for the collection, processing, or use of personal data by third-party websites or services.
9. Changes to This Privacy Policy
The Company may revise this Privacy Policy when necessary due to legal requirements, business needs, or other circumstances. If changes are made to this Privacy Policy, the Company will update the effective date displayed at the bottom of this Privacy Policy and announce such changes in the relevant games or on the Company’s website. The Company may also, in certain circumstances, provide additional notice regarding changes to this Privacy Policy. Your continued use of the Services after such changes take effect constitutes your agreement to and acceptance of such changes. If you do not agree with any changes to this Privacy Policy, you may discontinue your use of the Services. The Company encourages you to review this Privacy Policy each time you use the Services to stay informed about the Company’s latest practices regarding the processing of personal data and how the Company protects your privacy.
10. Additional Terms Applicable to EU Users
(1) This section applies only to users located in the European Union. If you are located in the EU, this section shall prevail over any conflicting provisions of this Privacy Policy.
(2) Request for Deletion of Personal Data
You may state the reasons and request the Company to delete your personal data under the following circumstances. However, after deleting your personal data, the Company may not be able to provide the same services based on the operating model of the Services or related games:
a. You believe that the Company is processing your personal data unlawfully.
b. You believe that the Company no longer needs to collect or process your personal data.
c. You wish to withdraw your consent to the Company’s collection and use of your personal data.
(3) Retention of Personal Data
In order to provide the Services or related products to you, or as required or permitted by applicable laws, the Company will continue to retain your personal data. If you request deletion of your personal data pursuant to the preceding paragraph, after confirming that your request has reasonable grounds, the Company will notify you of the date of deletion.
(4) Data Portability
Regarding the personal data you have provided to the Company, you may request the Company to provide such data to you in a structured, commonly used, machine-readable, and interoperable format, or to transfer such data to a third party designated by you. If you wish the Company to transfer the data to a third party designated by you, please ensure that such third party understands that the Company may only transfer the data where technically feasible. The Company shall not be responsible for the security of personal data received by such third party or for the processing of such personal data by such third party.
(5) Right to Object to Profiling
You may object to the Company creating a personal data profile based on your personal data. Please provide detailed reasons for your objection to the extent possible. After the Company confirms that your objection has reasonable grounds, the Company will cease creating such personal data profiles, unless otherwise required by law. However, after you object to the Company profiling your personal data, the Company may not be able to provide the same services based on the operating model of the Services or related games.
(6) Request for Restriction of Processing
You may request the Company to restrict the processing of your personal data in the following circumstances:
a. When the Company is about to delete your personal data, but you request that the Company retain your personal data.
b. You have concerns regarding the accuracy of your personal data, and the Company is verifying the accuracy of such personal data.
c. The Company no longer needs your personal data; however, you require the Company to restrict processing for the establishment, exercise, or defense of legal claims.
(7) Transfer of Personal Data Outside the EU
Your personal data may be transferred outside the EU. The Company will take appropriate measures in accordance with applicable laws to ensure that data recipients are subject to confidentiality obligations and implement measures such as appropriate contractual safeguards to ensure that data recipients protect and process your personal data in compliance with applicable personal data laws.
(8) Children’s Data
The Company will not provide games and related services to children under the age of 16 located within the EU, or children below the age at which parental consent is required for the processing of personal data under the laws of their country or region of residence (collectively referred to as “Children”). The Company will not knowingly collect or retain any personal data from Children. The Company will also delete any personal data that the Company determines was provided by Children.
11. Push Notifications/Alerts
The Company may send push notifications or alerts to your device. You can change your device’s notification settings at any time to stop receiving such notifications. The Company will only send push notifications or alerts containing promotional content if you have previously enabled or consented to receive promotional notifications on your device.
12. If you have any questions regarding this Privacy Policy, please contact the Company’s department responsible for personal data management using the following contact information: [contactus@aktsk.com]
If you are a user located in the EU, you may also contact us regarding any questions about this Privacy Policy using the following contact information:
a. Personal Data Protection Contact: [Akatsuki Taiwan Inc. Marketing Team]b. Contact Information for the EU Representative: [contactus@aktsk.com]