SUDOKU KINGDOM - PRIVACY POLICY

Article 1 (Definition)
1. "Personal Information" means any data relating to an identified or identifiable natural person, including, but not limited to, customers' names, addresses, birth dates, telephone numbers, e-mail addresses, user IDs, device IDs, IP addresses, location, and other online identifiers.
2. "Processing" means any operation or set of operations which is performed on Personal Information or on sets of Personal Information, whether or not by automated means, such as collection, recording, organization, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction.
3. "Services" means any of the Company's various Application, software, websites, accounts, features, content, and activities that are operated by Company and/or post or link to this Privacy Policy.

Article 2 (Application of the Terms)
1. By installing and using the Services, Customer consent to this Privacy Policy and the collection, use and sharing of the Personal Information described in this Policy. If Customer do not agree, do not install the Application or use the Services.
2. Customer may withdraw above agreement at any time by sending an email to the following address: info-sudoku@ohtegames.com

Article 3 (Compliance with Legislation)
The Company will comply with the Act on the Protection of Personal Information and this Policy with respect to the acquisition, use, and handling of Personal Information.

Article 4 (Acquisition of Personal Information)
The Company will acquire Personal Information via appropriate means, and utilize it only for the purposes set forth below; provided, however, that there may be cases in which the Company will separately announce or send notice of purposes of use other than those set forth below:
(1) to provide Customer with the Services (includes support, improvement and notifications for the Application);
(2) to delivery of advertisement related to products and services which the Company and advertisers who have contracted with Company ("Advertiser") provide.

Article 5 (Purpose of Use of Personal Information)
The Company will process customers' Personal Information in order to achieve the following goals:
(1) to provide the Services and enable customers' efficient use of the Services;
(2) for the purpose of conducting research, analysis, product service or development;
(3) to process and administer Customers' registrations as members of various parts of the Application;
(4) to respond to Customer's inquiries and provide customer support;
(5) to process details regarding Customers' use of the Application and the Services (including traffic data, game usage and gameplay data, location data and other communication data);
(6) to serve advertisements tailored to the preference and interests of Customers on the Services based on their use of the Services and/or on third-party sites and applications;

Article 6(Additional Processing)
1. In the case of Processing Customer's Personal Information for purposes other than the above, the Company will obtain Customer's agreement before doing so.
2. The Company reserves the right to monitor Customer's accounts and records to check any complaint or allegation of abuse, infringement of third-party rights or any other unauthorized use of the Application.

Article 7 (Retention Period)
The Company will retain Customer's Personal Information for as long as we reasonably require such data to provide you with the Services in accordance with this Privacy Policy or as otherwise may be required for legal compliance purposes.

Article 8 (Safety Control Measures)
The Company will take all necessary and appropriate safety control measures when handling Personal Information in order to prevent the divulgence, loss, or damage thereof, while also striving to improve these measures.

Article 9 (Supervision of Employees and Trustees)
1. The Company will appoint an administrator within each department to handle Personal Information and to ensure the proper management of Personal Information. Personal Information will be handled solely by properly trained officers and employees of the Company who are authorized to access such Personal Information.
2. There may be cases within the scope necessary for the usage purpose in which the Company entrusts the handling of Personal Information to a third party. In such cases, the Company will obligate the trustee by way of a contract, etc. to handle the Personal Information properly, and will exercise necessary and appropriate supervision over the trustee.

Article 10 (Links)
Application may contain links to external sites. Clicking on a third-party link will redirect you to that site. Please note that we have no control and responsibility for the content and Privacy Policies of third-party sites or services.

Article 11 (Disclosure to Third Parties)
1. The Company will not, except in the following cases, disclose or provide Personal Information to a third party without obtaining the prior consent of the individual in question:
(1) Cases in which it is necessary for the Company to fulfill legal obligations imposed on business entities, etc.
(2) Cases in which the Company has judged that it is appropriate for a group company of Company to handle the content of an inquiry;
(3) Cases in which disclosure is required by a court, prosecutor's office, police, bar association, consumer affairs bureau or other institution, entity, or individual similar thereto;
(4) Cases in which there is due course, such as for the protection of the life, property, honor, or credit of the individual supplying the Personal Information or other third party;
(5) Cases in which the Personal Information is used in a way that does not lead to the identification of the person; and
(6) Any other case in which disclosure is admitted by legislation or regulations.

Article 12(Transfers of Personal Data to Third Parties and/or Other Countries)
1. The Company may disclose Customer's Personal Data to third parties such as the subsidiaries and affiliates of the Company, as well as to third-party cloud vendors and outside contractors of the Company in order that such third parties may assist in providing the Services.
2. In the event Company sells or buys any business or assets, Company may disclose Personal Data to the prospective seller or buyer of such business or assets.
3. Company may also disclose Personal Data to a third party if Company reasonably believes doing so is necessary to comply with a legal order or obligation, to enforce or apply Company's Terms of Use or other contracts, or to protect another user's or other third party's rights, property or safety (including exchanging information with other companies and organizations for the purpose of fraud protection and credit risk reduction).
4. Company may aggregate Customer's Personal Data with other data so as to render it anonymous, and may disclose such anonymous and aggregate data to third parties.
5. Customer's should be aware that the information Company collects, including Personal Data, may be transferred, processed, stored and used internationally, in countries or regions other than countries located outside 　Customer's country of residence. The data protection laws in these countries may differ from those of the country in which Customer is located (for example, many of the rights provided in the EEA to the data subjects of the data are not given), and your Personal Data may be subject to access requests from governments, courts or law enforcement. By using the Services and/or providing Company with Personal Data, Customer consent to the transfer of Personal Data as set forth in this Privacy Policy.

Article 13 (Collection of Personal Data)
The Company collect and process the following Personal Information when User using the Services:
(1) Data automatically collected from the Services
(2) Customer's device type and model, manufacturer, operating system platform and version, general location (region, country, city, etc), Application version, start and end of advertisement browsing, Application play status (stage start, end, and operation information)
(3) IP address and Advertising ID (if you use Apple devices, IDFA / if you use Android devices, AAID)
(4) Information Customer provide when contacting Company
(5) Contact information such as Customer's name and email address, and any other information we need to provide support
(6) Data obtained from Advertiser

Article 14 (Children data)
1. Company never knowingly or willingly collect any personal data concerning children under 16 years of age.
2. In the event that anyone under the age of 16 wishes to use the Services, the Company asks them to make sure that the consent is given or authorized by their guardian.
3. After the Customer reaches the age of 16, consent from the customer's parent or legal guardian for the processing of the Customer's Personal Information can be confirmed, modified or withdrawn.

Article 15 (Customer's Rights to Personal Data)
1. Customer may request access to Customer's Personal Data at any time by sending an email to info-sudoku@ohtegames.com. In addition, Customer may request that the Company delete, stop Processing or correct errors in your Personal Data and request for your Personal Data to be provided ("data portability") by sending an email to the same address.
2. In principle, only the individual in question may request the disclosure, correction, addition, deletion, termination of use, and erasure of their Personal Data.
3. The Company will, to a reasonable extent, respond as swiftly as possible only in cases in which it has received a request based on the "Procedures for Requesting the Disclosure, etc. of Personal Data" set forth separately below.
4. Customer may lodge a complaint with any data protection authority that has jurisdiction over the Company and/or is located in your place of residence or employment.

Article 16(Inquiries concerning Personal Information)
1. In principle, only the individual in question may request the disclosure, correction, addition, deletion, termination of use, and erasure of their Personal Information.
2. The Company will, to a reasonable extent, respond as swiftly as possible only in cases in which it has received a request based on the "Procedures for Requesting the Disclosure, etc. of Personal Information" (Article 17).
3. With respect to inquiries or consultation regarding this Policy or the Company's handling of Personal Information (how to request the disclosure of Personal Information, etc.), please send an email info-sudoku@ohtegames.com

Article 17(Procedures for Requesting the Disclosure, etc. of Personal Information)
(1) How to make a request
When requesting the disclosure, correction, addition, deletion, termination of use, or erasure ("Disclosure, etc.") of provided personal information, you should send the following documents by postal mail or e-mail.
◆In cases when the individual in question makes the request
(i) Formal identification showing the individual's full name and address
(a) Copy of a driver's license
or
(b) A copy of each of any two of the following: Health Insurance Card, Resident's 　　Card, Passport, Certificate of Alien Registration, Pension Booklet, Public Utility Receipt, Notary form, etc.
◆In cases when a representative of the individual in question makes the request
(i) Formal identification showing the individual's full name and address
(a) Copy of a driver's license
or
(b) A copy of each of any two of the following: Health Insurance Card, Resident's Card, Passport, Certificate of Alien Registration, Pension Booklet, Public Utility Receipt, Notary form, etc.
(ii) Formal identification showing the representative's full name and address
(a) Copy of a driver's license
or
(b) A copy of each of any two of the following: Health Insurance Card, Resident's Card, Passport, Certificate of Alien Registration, Pension Booklet, Public Utility Receipt, Notary form, etc.
(iii) A letter of proxy from the individual (in cases when the request is made by the legal representative of a minor or adult ward, a copy of a document that makes clear the connection with the individual, i.e. family register; abridged family register; or certificate of residence, may be submitted in place of a letter of proxy)
(2) Mailing address
Ohte,Inc.
22-14 Sakuragaokacho,
Shibuya-ku, Tokyo,150-0031, Japan
(3)E-mail address
info-sudoku@ohtegames.com
(4) Charge for requests
The Company will charge a separately specified fee for requests for notification of the disclosure and purpose of use of Personal Information.
(5) Other
(i) Personal Information acquired due to a request for Disclosure, etc. will only be handled within the scope necessary for responding to said request for Disclosure, etc.
(ii) Note that the Company will not return any documents that it has received.
(iii) The Company will appropriately administer and dispose of all documents and data after we have handled the request for Disclosure, etc.

Article 18 (Continued Undertaking)
The Company will strive continuously to improve its handling of Personal Information through the establishment and review of internal regulations and implementation of training programs.

(additional clause)
The Terms shall be effective as of May 01, 2022.