Personal Information Protection Policy (Privacy Policy) for Apple Arcade Titles

As KITERETSU Inc., ("Company") handles the personal information, etc. ("User Information") in connection with the services, goods, and websites it provides ("Company Services"), it considers the protection of such personal information and privacy to be one of its most important duties, and in order to adequately safeguard the User Information, hereby establishes the following Personal Information Protection Policy, to work for the protection of such information:

  1. When collecting User Information from the customers, the Company will clarify the purpose of use thereof, and will only collect the same to the extent necessary.
  2. The Company will use the User Information collected from the customers only for the purposes of use as described below or within the purpose to be separately agreed upon by the customers.
  3. The Company will take appropriate measures to prevent and cure any unauthorized access to, or loss, deletion, falsification or leakage of User Information.
  4. The Company will comply with the laws regarding protection of personal information, as well as all other relevant laws, and other rules.
  5. The Company will appropriately manage the handling of User Information by appointing a person to be in charge of the protection and management thereof;
  6. In order to improve and enhance the User Information protection system, the Company will comply with the "Personal Information Protection Regulations" and improve the same on a continuous basis.

Information we collect

We collect the following information:

(1) Game play information, which contains non-personal gameplay data, such as save state data and game achievement data. The data are being saved locally at your device(s), and you can choose to share the game play information across other devices through Apple's Game Center and iCloud. If you choose to connect to Game Center and iCloud, the data are sent to Apple iCloud for saving gameplay data, or Game Center for saving achievement data, which enables you to continue playing the game on different devices that have been logged into the same iCloud and Game Center accounts. The data uploaded to your iCloud account is only available to you. If you are using Game Center, the game sends achievements and leaderboard high score to Game Center. We do not receive or store this gameplay information on our servers. The data sent to iCloud and Game Center are maintained by Apple. Please refer to Apple's privacy policy on how apple stores its customers' iCloud and Game Center data. Player can decline to store data in iCloud or to send data to Game Center. To turn off iCloud, you must turn off iCloud in Apple settings for the game. To stop sending data to Game Center, you must sign out of Game Center in apple settings. As a result, you can only play in offline mode where your saved data is not shared across other devices, and also your progress in game leaderboard will not appear.

(2) If you provide your email to us when contacting us, email address, any information contained in such email, including your contact information, and the device information (such as model, processors, device ID, OS version).

(3) Anonymous game analytics data for players who manually opt-in to help us improve the game. The data sent is not in any way connected to your personal identifying information. Player can decline sending collection of level data by going to settings in the game and choose to opt-out for sending data analytics. We store anonymous game analytics data (if permitted by the player) in Amazon Web Services (AWS) cloud.

Purposes of Use of User Information

The Company may use User Information collected from the customers for the following purposes:

  1. To carry out authentication procedures in the Company Services;
  2. To manage and operate the Company Services, to make various communications made within the Company Services, or anyhow to provide the Company Services;
  3. To, without limitation, understand, analyze, or study the needs and tastes of the customers, or to improve the Company Services or to develop new services;
  4. To provide customer support regarding the Company Services, to respond to comments and questions from the customers, and to dispatch gifts;
  5. To prevent unauthorized use of the Company Services;
  6. With regard to the use of the Company Services, to generate statistical data processed into a form in which identification of specific individuals is not possible;
  7. To improve game quality
  8. To enhance experience of the game
  9. To, without limitation, understand, analyze, or study the needs and tastes of the customers, as well as to develop new services, together with the content business-related partner companies carrying out the business in collaboration with the Company.
Manager of User Information

User Information collected by the Company will be managed at the headquarters of KITERETSU Inc., located at Park Axis Aoyama 1-chome Tower #2209, 1-3-1, Minami-aoyama, Minato-ku, Tokyo.

Implementation of Security Management Measures

In order to appropriately handle the customers' User Information and to prevent the loss, deletion, falsification and leakage, etc., of User Information, the Company will establish a security management system and appropriately supervise its employees, etc., who handle User Information.

Provision of User Information to Third Parties

The Company will not provide any third party with User Information of any person without obtaining the consent of such person; provided, however, that the Company may disclose User Information as required by law, or to those entrusted with its services to the extent necessary for achieving the purpose of use of the same. The services entrusted will include, without limitation:

・ In the case of the customer support services being outsourced to external business operators;

Sharing of Information

The Company will share User Information that is deemed necessary for the above-mentioned purposes of use for the purposes provided in ""Purposes of Use of User Information"" above, with its subsidiary/affiliates or other group companies.

Personal Information of Minors

The Company collects, uses, and discloses data from underage users in the same way as for other users, as described in this policy. The use of underage users data is limited to support internal operations of the game. If you are a parent or guardian of a child under the age of 13 or under the age of consent in your jurisdiction, who wish for this information to be deleted, please contact us at privacy@kiteretsu.jp.

Data Retention

Your personal information will be retained by us for the duration of your use or access to our games and may be retained until we no longer require such data for the purpose for which it was collected or until required to be deleted by laws applicable in your jurisdiction.
The users can delete their game progress from their iCloud and/or Game Center account at any time. Otherwise, the game progress will be retained. Please refer to Apple's privacy policy on how apple stores its customers' iCloud and Game Center data. Game progress saved locally is retained unless the player deletes (uninstall) the game from their device(s).

Notification, Disclosure, Amendment, Addition, or Deletion of User Information, as well as Service Suspension

If any person requests, with regard to his/her User Information owned by the Company, that the purposes of use thereof be notified or User Information to be disclosed, amended, added to or deleted, the Company will comply with such request as soon as reasonably possible upon verifying the identity of the person.
If any person requests suspension of the Company Services that use User Information, the Company will comply with such request promptly upon verifying the identity of the person.
For the procedures to be taken in such cases, please contact the department in charge as set forth at the bottom hereof.

Change to this Personal Information Protection Policy; Contact Information, etc.

The Company may change the content of this Personal Information Protection Policy without prior notice in order to appropriately protect the customers' User Information or in line with the amendment of laws and ordinances, including in the event of any change in the content of the business of the Company.
Any change will be announced in an easily comprehensible manner, so please confirm the latest content on a regular basis.

Department in Charge of this Personal Information Protection Policy
Contact Information: KITERETSU Inc., Administration Department
Email address: privacy@kiteretsu.jp