Privacy Policy (for the users in SEA)

Effective date: 01 April 2019

In this Privacy Policy, "DeNA", "we", "us", or "our" means DeNA Hong Kong Limited.

Your privacy is important to DeNA. We designed our Privacy Policy to cover how we collect, use and share your information in connection with use of our multi-region entertainment software, and media dedicated to that software ("Services"). By using our Services, you agree to our collection and use of your information, including your personal information, as described in this Privacy Policy.

So please take a moment to learn the What and the Why, the When, the How, and other important matters about the information we collect and how we use and share it. If you have any questions, please contact us.

The What and the Why

In the course of using our Services, you may provide us, directly and indirectly, with both personal and non-personal information. Personal information is information that can be used to identify you as an individual. Non-personal information is information that does not permit direct association with you. Both personal information and non-personal information may be used alone or in the aggregate with information collected from other users. Certain non-personal information would be considered a part of your personal information if it were combined with other identifiers (e.g., combining your zip or postal code with your street address) in a way that enables you to be identified. But the same pieces of information are considered non-personal information if they are taken alone or combined only with other non-personal information (e.g., your viewing preferences).

Some data is necessary for enabling us to provide the registration to and usage of our Services. This includes the data below.

Item	Types of Data	Purpose of use
Basic information	E-mail address Language Nationality	To help us develop, deliver, and improve our Services, including the following aspects of our Services : *messaging and other communication to and with users *the creation, updating, accessing, and maintaining of lists of friends or contacts *transactions for and use of virtual currency and virtual items *social communication and user-interactive features *Providing end-user support To prevent and take measures against fraud, illegal activities, infringement of our rights or interests, or breaches of any related law, regulations, and this Privacy Policy. To audit and analyze data for technical administration, to improve our Services, and for end-user communications.
IP address	IP address
Cookies	Cookies Session ID Browser ID
Data about your account and use of Services	Services user ID Services username (nickname) Password Services data Services use related activities information Services crash log data Posting on the chats, wall and other forums Your message to the Services Application version User agent
Information from Third Parties	Facebook user ID Facebook username Google ID
Information we collect from your device	OS (version) Model of device

In addition to the above data, we would also like to use the below data for general advertisement purposes and to inform you of our future offers and similar products.

Item	Types of Data	Purpose of use
Basic information	Profession/Education background City E-mail address Address of residence	*The delivery and targeting of advertising in the Services *Tracking of advertisement fulfillment metrics in the Services *Recommending Services-related products or services of interest directly to you For market research purposes that support our efforts to deliver a more valuable service to our community of users, including using your information to contact you with announcements, newsletters, and promotional materials related to our Services or to offer you opportunities to participate in surveys, contests, or sweepstakes via our Services.
IP address	IP address
Cookies	Cookies
Data about your account and use of Services	Services data Services use related activities information (including payment amount)
Information from Third Parties	Facebook user ID Facebook username Google ID
Information we collect from your device	IDFV/Android ID IDFA/AAID MAC address OS (version) Model of device Country and region

We will try to process your personal information into non-personal information with technical methods. Such de-identification will protect you not to be identified as an individual.

The When

Direct interaction and use of our Services

Your information is collected by us when you directly interact with our Services and otherwise through use of our Services via your Device (as described in the “How” section below).

Social Plug-ins

・Facebook

- Website: https://www.facebook.com/

- Privacy Policy: https://www.facebook.com/about/privacy/update

・Google+

- Website: https://plus.google.com/about

- Privacy Policy: https://policies.google.com/privacy

Your information may also be made available to us when you register with any SNS for use of our Services and/or permit any SNS to share any of your information with us in connection with your use of our Services. By accepting an SNS's applicable terms, you agree and consent to the SNS making such information available to us on those terms.

Promotion services

If you actively choose to participate in a Promotion, we may request that you provide us with personal information such as your email address or postal address in order to administer your participation in the Promotion.

Duration of Storage

We will not keep your personal information any longer than needed for the purpose it was collected or than is necessary for legal or legitimate business purposes.

The How

As already mentioned, we may collect information from you when you directly interact with our Services and otherwise indirectly through your access to or use of our Services.

Direct interaction

Direct interaction includes such actions as creating a username, providing an email address, creating a friends' list, chatting with other users, or posting to walls and other forums through our Services. It also includes the sending of pre-formatted messages for various purposes such as to challenge friends to beat a high score. We may store the email address of the friend that you choose to email via our Services, but would only do so for social purposes such as generating friend recommendations. You specifically agree that we shall have the right, but not the obligation, to collect and store the information referred to in this paragraph.

Information from Third Parties

We may also collect your information from third parties who provide it to us, including other users of our Services.

Cookies

A cookie is a small string of text placed on your Device. In addition to strictly necessary cookies that enable us to provide our Services (such those that provide your SNS log-in status when that account ID is linked to functionality on the Services), we may use both performance-gauging and functionality-gauging cookies. Performance-gauging cookies reveal how you use the Services, for instance, which content is the most popular, how much time users are spending there, and what advertising is relevant to you, which helps us provide an optimized experience (we may engage third parties to carry out this analysis, and they may set their own "third party" cookies-see "The Who" for more). Functionality-gauging cookies enables us to remember certain choices you make in interacting with the Services, for instance, any geographic location, language, or fonts you choose, which helps us tailor the Services to your preferences. Neither performance-gauging cookies nor functionality-gauging cookies collect information in any way that personally identifies you.

Except for cookies strictly necessary for enabling us to provide our Services, you have the option to disable cookies stored on your browser by changing the options in your browser to stop accepting cookies, or to prompt you before accepting a cookie from the content you visit, or by installing opt-out cookies offered by third parties. Note that "flash cookies", which are different from HTTP cookies, may require different treatment for removal of disablement depending on the version of the browser used. If you do not accept cookies, you may not be able to view or use parts of our Services due to limited functionality. Some cookies we use may be stored using a web-browsing component other than a browser application--these cannot be disabled on your Device, but the information collected does not personally identify you, and does not permit tracking between Services. We may generate and collect Session ID and Browser ID by cookies for the user identification.

Recording information from your Device

In using our Services, our servers record information sent from your Device, which may include information such as device type, mobile carrier, unique device identifier ("Device Number"), Internet Protocol ("IP") address, email address, browser type, language, Internet service provider, network status, time zone, geo location, referring and exit pages, time spent, information searched for, time and date stamp, clickstream data, and other statistics on your use of our Services; for some games or other software no Device Number is recorded but in those and other cases we may have access to a generated and non-permanent unique identification number functionally matched with your Device ("Matching Number").

The Who

Our Responsibility for Our Collections

While we will collect and use your information as explained in this Privacy Policy, as a user of our Services you may be permitted to use and create your own profile, connect with other users of our Services, and send messages and transmit information through various channels. Please remember that any communications you have via our Services, depending on, for example, the functionality of the Services used, may reveal information such as any SNS and/or Services profile(s) you create (including your username(s), profile image(s), and profile status/comments, "Profile") and the content of your communications, making this information publicly available to other users. We are not responsible for the activities of other users or other third parties with whom you choose to provide your information or otherwise interact.

Persons and Entities with Whom We May Share Your Information

To the extent you have agreed in the consent form in section “The What” above, we may share your information as follows:

-With Third Parties for Industry Analysis and Advertising

You agree that we may share technical information related to your Device (such as IP address, Matching Number, or Device ID), aggregated non-personal information, and anonymous information with advertisers, ad networks, and analytics analysis entities ("Ad Entities") with whom we have strategic relationships, and Ad Entities may also be permitted to collect such information via cookies and other tracking technologies. This information may be used to undertake user trend analyses, demographic profiling, and analytics, and to provide to you tailored and personalized ads and advertising (behavioral advertising). Please note, though, that some Ad Entities also act as Service Providers (defined below) for us, and in those cases, we may share your information as explained below.

-With our Service Providers

Sharing of your information may also occur where we engage or employ service providers, vendors, or other third parties to help us provide our Services (each a "Service Provider") (e.g., improvement of our Services' features, promotion and marketing, administration, analytics, customer service, cloud storage, hosting, and other related services), to provide the Services on our behalf, or to assist us in analyzing how our Services are being used. Our Service Providers may have access to your personal information only to perform these tasks on our behalf, and they are obligated not to disclose or use your personal information for any other purpose.

-With Certain Third Parties in Special Circumstances

At times, we may disclose information about you to law enforcement officials or private parties as we believe necessary or appropriate to respond to claims and legal process (including subpoenas), to protect the property and rights of DeNA or a third party, to protect the safety of the public or any person, or to prevent or stop activity we may consider to be, or to pose a risk of being, illegal, unethical, or legally actionable activity.

The Where

You understand and agree that we may transfer your information to and process it outside your country of residence. Your consent to this Privacy Policy by accessing or using our Services represents your consent to such transfer and processing.

The transfer of personal data to recipients outside your country of residences is generally prohibited unless:

―the jurisdiction in which the recipient is located is deemed to provide an adequate level of data protection;

―the data exporter puts in place appropriate safeguards (e.g. binding corporate rules; contractual arrangements with the recipient of the personal data, using, for example, the standard contractual clauses approved by related laws and regulations, adherence to a code of conduct or certification mechanism together with obtaining binding and enforceable commitments from the recipient) or

―a derogation or exemption applies (e.g. where an individual has explicitly consented to the proposed transfer after having been provided with all necessary information about the risks associated with the transfer);

―a de-identification of personal information is conducted before the transfer.

Changes to Privacy Policy

We reserve the right to change this Privacy Policy at any time. If we change this Privacy Policy in a material way, we will give notice of that in the Services, and/or by email to any email address we may have for you at that time. Your use of our Services after we have changed the Privacy Policy will indicate your consent to the updated Privacy Policy.

Other Important Matters

Your Rights

For the exercise of any of your rights mentioned below, please contact us.

Personal Information from Children

 If you are under the age of 18 or the age of legal majority where you access our Services, you represent that your legal guardian has read, understood, and agreed to this Privacy Policy.

None of our Services is intended for children and we only knowingly collect personal information from, or store personal information of, children under your guardian’s approval.

We will take all reasonable efforts upon notice or discovery to erase or destroy any such personal information that may have been collected or stored by us without your guardian’s approval.

Withdrawal of Consent

You can withdraw your consent for the collection, usage and storage of your information and data free of charge and at any time by giving us reasonable notice.

Upon receiving your request, we will inform you of the likely consequences of the withdrawal of your consent, and will cease to process your information therefrom, unless otherwise permitted or required by applicable laws and regulations. Please note that if you withdraw your consent to any or all usage of your data, depending on the nature of your request, we may not be able to provide to you our Services anymore.

Right of Information, Correction

You have the right to request anytime information about the data stored by us concerning you, their source and their recipients as well as the purpose of the data processing. You further have the right of correction, and the right of deletion of the data stored with us anytime.

Right to Restriction of Processing

You have the right to obtain restriction of procession when:

(a) the accuracy of the personal data is contested by you, for a period enabling us to verify the accuracy of the personal data;

(b) the processing is unlawful and you oppose the erasure of the personal data and request the restriction of their use instead;

(c) we no longer need the personal data for the purposes of the processing, but they are required by you for the establishment, exercise or defense of legal claims;

(d) you have objected to processing your data pending the verification whether the legitimate grounds of us override those of yours.

Opting-out from Promotion

For a Promotion, you have the option to opt out at any time from participation in such Promotion and the receipt of any related communications by following unsubscribe instructions provided in the relevant communications, or by selecting not to receive communications from us where the relevant media service offers that option.

Deleting a Matching Number

You may have the option of deleting a Matching Number by performing a dedicated reset or a Device factory reset from the settings of your Device. You understand that by deleting a Matching Number any and all data you had prior to the reset may be lost and irretrievable, and that you may not be able to view or use portions of our Services due to limited functionality.

Push and Local Notifications

Unless you indicated otherwise at installation or chose not to receive push and local notifications where the option is made available to you, you agree that we may send push and local notifications to your Device concerning updates, events, and special offers for our mobile games and other mobile applications of the Services installed on your Device. Please note that where available you may have the option of deactivating push or local notifications by changing the settings of the game/application or of your Device.

Protecting Your Information

We take your privacy very seriously and employ reasonable administrative, physical, and electronic measures to safeguard information received from you and held by us against identity theft and unauthorized access or alteration. In addition, we will take reasonable steps to assure that third parties to whom we transfer any data will provide sufficient protection of your personal information. We do not and will not, at any time, request your credit card information, your username, login password, or any national identification numbers in a nonsecure or unsolicited communication (e.g., via e-mail, mobile device).

We will make any legally required disclosures of any breach of the security, confidentiality, or integrity of your unencrypted electronically stored "personal data" or "personal information" (as defined in applicable statutes on security breach notification) to you via email or conspicuous posting on our website in the most expedient time possible and without unreasonable delay, consistent with (i) the legitimate needs of law enforcement; or (ii) any measures necessary to determine the scope of the breach and restore the reasonable integrity of the data system.

If you have any concerns with the way we collect and handle your personal information, or would like to correct or request that we delete such personal information held by us, please contact us. We will use commercially reasonable efforts to honor your request; please note, though, that at a minimum we may retain an archived copy of your records as required by law or to send necessary communications to you under this Privacy Policy. You understand that deletion of your personal information may result in you not being able to view or use portions of our Services which depend on such information.

Other Websites and Services

Our Services may contain links to other websites and online services or offers from third parties. For example, our Services may include offers from third party advertisers or the ability to engage in transactions with such entities. If you choose to participate in offer-linked information requests or "click on" an advertisement or another third party link, you may be directed to that third party's website or service and/or be prompted to provide personal information in connection with such activity.

The fact that we link to a third party website or service is not an endorsement or representation of our affiliation with that third party, nor is it an endorsement of such third party's privacy or information security policies or practices or their compliance with any laws. We do not exercise control over third party websites or services, and this Privacy Policy does not apply to information collected by them, including Ad Entities. These other websites or services may place their own cookies or other tracking devices on your computer or mobile device, or collect data or solicit personal information from you. Other websites and services follow different rules regarding the use or disclosure of the personal information you submit to them. We encourage you to read the privacy policies or statements of the other websites and services you use and the terms of the offers in which you participate. You agree that we are not responsible for, nor will we be liable to you or any third party for, your interaction with such third parties or the information requests initiated by such third parties or the subsequent use, treatment, or dissemination of the information you provide to them.

If you have any questions, inquires, requests, or complaints concerning this Privacy Policy or our information collection practices, or wish to exercise any of your legal rights, please contact us at kf@mobage.tw or call us as +886-2-27826996 from 9:30 to 18:30 on working days.