GUNGHO ONLINE ENTERTAINMENT, INC. U.S. PRIVACY POLICY

(Effective Date: November 20, 2025)

GungHo Online Entertainment, Inc., a Japanese corporation or one of its wholly owned subsidiaries, joint ventures or affiliates (“Company,” “our,” or “we”) owns and operates this website (our “Website”). We respect the privacy of users of our Website (“you” or “your”) and have adopted this Privacy Policy (this “Policy”) to explain what information we collect from or about you through our Website and how we use, maintain, protect, and disclose that information.

Please read this Policy carefully to understand our policies and practices regarding your information. By accessing or using our Website, except where prohibited, you agree to this Policy, which is incorporated into our Terms of Service (gungho.jp). If you do not agree to this Policy, you may not use our Website.

1. General Policy. We respect your privacy and are committed to protecting your “Personal Data,” which we define as information relating to an identified or identifiable individual like you. Personal Data does not include aggregated or anonymized information, provided it does not and cannot identify you. This Policy applies only to information we collect through our Website. Except where otherwise noted, it does not apply to information we collect through other channels. It outlines what Personal Data we collect about you through our Website and how it is used. It also explains how we process your Personal Data, who we share it with, how we look after it, and tells you about your privacy rights and how the law protects you.

2. Supplemental Privacy Notices. In addition to the provisions in this Policy, which are generally applicable across all jurisdictions, if you are resident in one of the following locations, please review the applicable supplemental privacy notice (each a “Supplemental Privacy Notice”) listed below.

Supplemental U.S. Privacy Notice listed at the bottom.

3. What information do we collect about you? We collect information about our customers, prospective customers, vendors and business partners, and Website visitors. The type of Personal Data we collect depends on the nature of our relationship with you and the legal requirements in your location. We endeavor to collect only information that is relevant for the purposes of processing. The table below sets out the various categories of Personal Data that we may collect.

CATEGORY OF PERSONAL DATA
Contact Information

REPRESENTATIVE DATA ELEMENTS
・Name
・Postal address
・Telephone number
・Email address

INDIVIDUAL TO WHICH DATA APPLIES
Vendors, customers and other partners

CATEGORY OF PERSONAL DATA
Unique IDs

REPRESENTATIVE DATA ELEMENTS
・Device identifier
・Cookie ID

INDIVIDUAL TO WHICH DATA APPLIES
Vendors, customers and other partners
Website visitor

CATEGORY OF PERSONAL DATA
Financial Information

REPRESENTATIVE DATA ELEMENTS
・Bank account number and detail
・Payment card information
・Payment and reimbursement amounts

INDIVIDUAL TO WHICH DATA APPLIES
Vendors, customers and other partners

CATEGORY OF PERSONAL DATA
Website Activity Information

REPRESENTATIVE DATA ELEMENTS
・Browing and search history
・Referring website addresses
・App usage data
・Device characteristics

INDIVIDUAL TO WHICH DATA APPLIES
Vendors, customers and other partners
Website visitor

・Personal Data of Minors. We do not knowingly collect, store, process, sell or share information from minors under the age of eighteen (18) years except as required by applicable laws.

・If we become aware or you or your parent/legal guardian identify to us or one our third party partners, that you are a minor under the minimum age of consent guidelines set by applicable laws, we will:

(a) Promptly obtain verifiable consent from your parent or legal guardian for the use your Personal Data, when required by applicable laws; and

(b) offer controls and choices to parents and legal guardians. For example, if your parent or legal guardian wishes to revoke their previously provided consent, we will provide them with an opportunity to review information collected from you or have that information deleted by contacting us via the process described in this Policy. If we become aware that you have provided us with Personal Data without verifiable consent as required by applicable law, we will delete any Personal Data we have collected, unless we have a legal obligation to keep it, and terminate your account and/or revert you to the age-appropriate experience, as applicable. If we make material changes to how we collect, store, use, sell, share or otherwise process Personal Data of minors under the minimum age of consent guidelines set by applicable laws, we will update this Policy accordingly and if applicable, notify such minor’s parents or legal guardians as required by applicable law.

4. How do we collect your information? We collect Personal Data directly from you and from other sources. The table below sets out the most common sources of Personal Data.

SOURCES OF PERSONAL DATA
Directly from you

REPRESENTATIVE COLLECTION METHODS AND CIRCUMSTANCES
・When you submit information through a survey or contest-entry form
・When you post a comment or feedback on our Website
・When you contact us

SOURCES OF PERSONAL DATA
Through automated means

REPRESENTATIVE COLLECTION METHODS AND CIRCUMSTANCES
・Automatically collected as you navigate our Website

SOURCES OF PERSONAL DATA
From third parties

REPRESENTATIVE COLLECTION METHODS AND CIRCUMSTANCES
・Marketing analytics service providers so that we can better understand our customers
・Website analytics firms that help us improve our Website
・Data aggregators from which we receive supplemental information about our customers
・Through your interactions with third-party social media platforms
・For vendors and business partners: In the course of due diligence prior to contracting with you, in order to comply with regulatory requirements

5. How do we use your information? We only use Personal Data when the law allows us to do so. We use Personal Data for the following purposes. To:

・Provide the information, products, and services you request;
・Provide you with effective customer service;
・Respond to your inquiries;
・Provide you with additional features on the Website based on your location;
・Send you transactional and administrative messages related to our products;
・Send you marketing communications (in accordance with your preferences);
・Invite you to participate in surveys and provide feedback to us (in accordance with any preferences you expressed to us);
・Improve the content, functionality, security and usability of our Website;
・Create insights and market intelligence (on an aggregated and non-personally identifiable basis) through analyzing the use our Website and our customers;
・Provide advertisements and monitor their effectiveness;
・Monitor security and prevent fraud;
・Comply with our legal and regulatory obligations; and
・Meet other purposes notified to you through our Website, an applicable agreement or another channel.

6. What is the legal basis for our data collection? We collect Personal Data about you for a variety of purposes based on the specific legal grounds described in the list below, unless your jurisdiction requires a special legal basis for the collection of personal data (for example, consent). Please refer to the Supplemental Privacy Notice applicable to your jurisdiction for additional information.

PURPOSE FOR COLLECTION
Delivering information, content, products or services that you request or purchase

LAWFUL BASIS
・To perform a contract or fulfill our obligation to provide products or services to you
・Our legitimate interests

PURPOSE FOR COLLECTION
Provide marketing communications about our products and services, or those of third parties, that may be of interest to you

LAWFUL BASIS
・Your consent
・Our legitimate interests

PURPOSE FOR COLLECTION
Understanding how you use our products, services, and Website in order to improve and further develop our products and services and the content, features, performance, and support available through our Websites

LAWFUL BASIS
・Our legitimate interests

PURPOSE FOR COLLECTION
Providing legal or service-related notices about our products, services, and Websites

LAWFUL BASIS
・To perform a contract with you
・Our legitimate interests
・To comply with a legal obligation

PURPOSE FOR COLLECTION
Detecting, preventing, and responding to fraud, intellectual property infringement, violations of our Terms of Service (gungho.jp), violations of law, or other misuse of the Websites

LAWFUL BASIS
・Our legitimate interests
・To comply with a legal obligation

PURPOSE FOR COLLECTION
Protecting our rights or the rights, property, and safety of others

LAWFUL BASIS
・Our legitimate interests
・To comply with a legal obligation

PURPOSE FOR COLLECTION
Complying with laws and regulations, judicial and administrative orders, or lawful requests from governmental authorities

LAWFUL BASIS
・To comply with a legal obligation

PURPOSE FOR COLLECTION
Conducting due diligence prior to entering into a contract with you

LAWFUL BASIS
・Your consent
・To perform a contract with you
・Our legitimate interests

PURPOSE FOR COLLECTION
Processing your application for employment with us, including administration of the recruitment process and evaluation of your candidacy

LAWFUL BASIS
・Your consent
・To perform a contract with you
・Our legitimate interests
・To comply with a legal obligation

PURPOSE FOR COLLECTION
Paying you for services you have provided to us, providing you with benefits to which you are entitled, or reimbursing you for expenses

LAWFUL BASIS
・To perform a contract with you

We may combine or aggregate any Personal Data we collect for any of the above purposes.  We may also anonymize your Personal Data in such a way that you may not be re-identified by us or any other organization. We may use such anonymized information for any purpose.

7. When do we share your information? We share your Personal Data with third parties for the purposes listed below.

CATEGORY OF THIRD PARTY
Our wholly owned subsidiaries , GungHo Online Entertainment America, Inc. (“GungHo America”)

REPRESENTATIVE PURPOSES FOR DISCLOSURE
GungHo America is required to comply with this Privacy Policy

SAFEGUARDS
GungHo America is required to comply with this Privacy Policy

CATEGORY OF THIRD PARTY
Service providers (contractors, professional advisors, insurers, finance providers or external auditors)

REPRESENTATIVE PURPOSES FOR DISCLOSURE
・To assist us in the functions and activities described above concerning the purposes for which we collect your Personal Data, including:

IT support, cloud platform and data hosting services to support the operating of our websites, mobile applications, document and workflow management systems and other systems and applications.

Payment processing.

Assistance with supply chain logistics and delivery of products you have requested/ordered.

Customer service activities, including managing queries and complaints.

Marketing support, including sending out email and other communications on our behalf.

Record-keeping and reporting to assist us in complying with laws and industry standards.

SAFEGUARDS
We execute contracts with service providers prohibiting them from using or sharing your Personal Data except as necessary to perform the contracted services on our behalf or to comply with applicable legal requirements

CATEGORY OF THIRD PARTY
Marketing Partners

REPRESENTATIVE PURPOSES FOR DISCLOSURE
To jointly offer products or services

SAFEGUARDS
We execute contracts with business partners that requires them to protect your Personal Data, and, where required by applicable laws, your Personal Data is only shared with your explicit consent

CATEGORY OF THIRD PARTY
Successor-in-interest (actual or proposed)

REPRESENTATIVE PURPOSES FOR DISCLOSURE
To continue to perform the functions and activities described above concerning the purposes for which we collect your Personal Data in the event of a proposed actual purchase, any reorganization, sale, lease, merger, joint venture, assignment, amalgamation, or other type of acquisition, disposal or financing of all or any portion of our business or any of the business assets or shares (including in connection with any bankruptcy or similar proceeding)

SAFEGUARDS
We will endeavor to direct the transferee to use Personal Data in a manner that is consistent with this Policy

・We do not sell your Personal Data. Nor do we share your Personal Data with third parties for their own marketing purposes, except with your consent and in connection with a jointly offered product or service.

・Personal Data Disclosure. We may disclose your Personal Data to anyone to whom disclosure is necessary to fulfill the purpose for which you provided the Personal Data.

・Aggregated Information. We share aggregated information about our users (e.g., statistical or demographic data) for any purpose. Such information could be derived from your Personal Data, but it no longer identifies you directly or indirectly. For example, we may aggregate usage data to calculate the percentage of users accessing a specific Website feature. However, if we combine or connect aggregated information with your Personal Data so that it can directly or indirectly identify you, we treat the combined information as Personal Data which will be used in accordance with this Policy.

・User Contributions. Content you post to the Website or in interactions with us through Facebook, Instagram, X (formerly known as Twitter), and other social networking platforms we make available to you (collectively, “User Contributions”), including those that contain Personal Data, are publicly accessible. In particular, please note that User Contributions, by definition, can be read, collected, used, and further disclosed by other users of our Website or social networking platforms. Please refer to our Terms of Service (gungho.jp) for more information about User Contributions. We strongly recommend you avoid sharing any personal details, and especially information that can be used to identify you directly such as your name, age, address and name of employer, in your User Contributions. We do not control how third parties who may access this publicly accessible information may use your User Contributions. We may use User Contributions for advertising campaigns and other promotions, and we share User Contributions with third parties for such purposes. Where such advertising campaigns or promotions involve Personal Data connected to your User Contribution, we will seek your consent before using the information.

・Links to Other Websites. Our Website may contain links to third-party websites or other online platforms. Clicking on these links may allow third parties to collect or share information about you. These links are provided for your reference and convenience only and do not imply any endorsement of the products sold or information provided through these websites, nor any association with their operators. We do not control these websites and we are not responsible for their data practices or privacy statements. Any information you provide to third parties on their websites is covered under their privacy and data collection policies and is not covered by this Policy. We urge you to review the privacy policy posted on any website you visit before using the website or providing any personally identifiable information.

・Social Media Platforms. Facebook, Instagram, X (formerly known as Twitter), and other social media platforms provide tools that many of our customers use and enjoy, and we include links to various social media platforms on our Website. If you interact with these social media platforms through our Website, including with our profiles on these platforms, your experience on those platforms will be governed by the privacy and other policies of those platforms. We encourage you to choose your privacy settings on those websites accordingly. If you log into our Website using your credentials from a social media platform, that platform also may receive data about the pages or content that you viewed on our Website.

・Third-Party Analytics Tools. Beyond the information you voluntarily provide to us directly, we utilize analytics tools, including third-party technologies such as Google Analytics, to collect information and help us understand how visitors engage with our Website. To learn more about Google Analytics, click here. To learn more about how Google uses data collected through partner websites or applications, click here.

・Cookies. We use cookies, web beacons, and similar tracking technologies (collectively, “cookies”) on our Website. Cookies are small amounts of data that are stored on your browser, device, or the page you are viewing. Some cookies are deleted once you close your browser, while other cookies are retained even after you close your browser so that you can be recognized when you return to a Website. You can find more information about cookies and how they work at www.allaboutcookies.org and www.youronlinechoices.com. Cookies on our Website are generally divided into the following categories:

- Essential Cookies: These cookies are essential in order to enable you to move around our Website and use its features, such as accessing secure areas of our Website.

- Analytical / Performance Cookies: These cookies include Google Analytics and they keep track of the pages that you visit and content you access, so we can tailor our Website to our users’ needs and improve the performance of our Website.

- Functional Cookies: These cookies remember the choices you make, such as language options or the region you are in. These cookies personalize your experience when you use our Website.

Generally, the information we collect using these cookies does not identify you personally. If, however, you have created a user identity, for example, by subscribing to our publications or filling out forms, we may link the information we collect using cookies to other information that identifies you personally. If you do not wish to receive cookies, you may set your browser to reject cookies or to alert you when a cookie is placed on your computer. You may also delete our cookies as soon as you leave our Website. Although you are not required to accept our cookies when you visit this Website, you will not be able to use all of the features and functionality of our Website if you set your browser to, or manually reject cookies.

・Third-Party Advertising Tools. Third parties may deliver cookies or other tracking technologies, including web beacons or tracking pixels, to your computer or mobile device for the purpose of tracking your online behaviors across nonaffiliated websites, and to deliver targeted advertisements on other nonaffiliated websites.

8. Where do we process your information? Your Personal Data may be stored and processed in your country, but it may also be transferred to or viewed in another country, including the U.S. and Japan, where allowed by applicable laws. We are part of a global company, and we may transfer your Personal Data in compliance with applicable laws to a recipient in another jurisdiction, or receive your Personal Data from another jurisdiction, if one of the following protections applies:

・The recipient is located in a jurisdiction in which the laws ensure a level of data protection that is equivalent to those in jurisdiction where data was collected.
・The recipient is subject to an approved certification mechanism or code of conduct with binding and enforceable commitments that provide appropriate safeguards for your Personal Data.
・We have put in place appropriate contractual safeguards to protect your Personal Data.
・The transfer to a foreign jurisdiction is expressly permitted by applicable laws.
・You explicitly consent to the transfer.

9. How do we secure your information? We have put in place reasonable security measures to prevent your Personal Data from unlawful or unauthorized processing and accidental loss, destruction, alteration or damage. Unfortunately, the transmission of information via the internet can never be completely secure. Subject to applicable law, we disclaim any guarantees, warranties or representations relating to maintenance or nondisclosure of any transmitted Personal Data.

・Data Retention. We will retain your Personal Data for as long as is necessary for the purposes listed in this Policy unless a longer period is required under applicable law, or a longer period is needed to resolve disputes or protect our legal rights or otherwise comply with legal obligations. When assessing the data retention period, we take into account the amount, nature, and sensitivity of the information, the potential risk of harm from unauthorized use or disclosure of the data, the purposes for which we process the data and whether we can achieve those purposes through other means, and the applicable legal requirements.

10. What are your legal rights? In certain circumstances, you have rights under data protection laws in relation to your Personal Data. Your rights may vary depending on the country in which you live, or the country in which we process your information. Please refer to the appropriate Supplemental Privacy Notice that is applicable to you for rights specific to your location. If you wish to exercise any of the rights set forth in the applicable Supplemental Privacy Notice, please review the process described therein, or to learn more about such rights, please contact us as indicated below.

11. How can you update your information? Please contact us as indicated below.

12. How can you change your marketing preferences?

・In General. We respect your right to make choices about the ways in which we collect, use, and disclose your Personal Data. We may ask you to indicate your choices at the time and on the page where you provide your information. Our Cookie Policy set forth above describes additional choices, such as your choice to opt out of receiving “cookies.”

・Opt-in or Opt-out Mechanism. In relation to marketing communications (including promotional emails) we may send you, we may provide you with an “opt-in” or “opt-out” mechanism depending on where you are located. An “opt-in” mechanism will provide you the opportunity to positively indicate that you agree to our sending you such further communications. An “opt-out” mechanism will provide you the opportunity to indicate that you do not want us to send you such further communications, and if you “opt-out” we will not send you any additional such communications.

・Email preferences. You can opt out of promotional emails we may send you. If such promotional emails are sent to you and you wish to stop receiving such emails, simply select “unsubscribe” located at the bottom of each communication. Please note that you cannot opt out of transactional emails, such as emails confirming a purchase made on our Website.

・Previously Expressed Preferences. You may be able to change previously expressed preferences regarding how we use your information. To do so, please contact us using the contact information provided below.

13. Changes to this Policy. We are continually improving and adding to the features and functionality of this Website, and to the services we offer through this Website. As a result of these changes (or changes in the law), we may need to update or revise this Policy. Accordingly, we reserve the right to update or modify this Policy at any time, without prior notice (unless prohibited in your jurisdiction), by posting the revised version of this Policy behind the link marked “Privacy Policy” at the bottom of each page of this Website. Your continued use of this Website after we have posted the revised Policy constitutes your agreement to be bound by the revised Policy. However, we will honor the terms that were in effect when we gathered data from you. We will also endeavor, where feasible, to notify you in advance of significant and material changes to this Policy. For your convenience, whenever this Policy is changed, we will update the “Revised on” at the top of this page. Be sure you check the “Revised on” date to see if this Policy has been revised since your last visit. You may access the current version of this Policy at any time by clicking the link marked “Privacy Policy” at the bottom of each page of this Website.

14. Terms of Service. This Policy and any applicable Supplemental Privacy Notices are incorporated into the Terms of Service (gungho.jp) that govern your use of this Website. If you do not agree to abide by the Terms of Service (gungho.jp) you may not access or use this Website.

15. Severability. If any provision of this Policy, including a Supplemental Privacy Notice, is declared invalid or unenforceable by a court having competent jurisdiction, that provision will be removed from the Policy without affecting the rest of the Policy, and the remaining provisions of the Policy shall continue to be valid and enforceable.

16. Contact Details. If you have any questions about this Policy or our privacy practices, please contact us at: GungHo Support

GungHo Online Entertainment, Inc.
Pacific Century Place Marunouchi, 1-11-1 Marunouchi, Chiyoda-ku,
Tokyo, 100-6221 Japan

(Effective Date: November 20, 2025)

This Supplemental U.S. Privacy Notice (this “Supplemental Policy”) describes the practices of GungHo Online Entertainment, Inc. and its affiliates, including GungHo Online Entertainment America, Inc. (“we,” “us,” or “our”) regarding the collection, use, and disclosure of personal information and provides instructions for submitting data subject requests. This Supplemental Policy applies only to information collected about consumers residing in California, Colorado, Connecticut, Virginia, Utah, or Texas (“consumer(s),” “Consumer(s),” “you,” “your”) and supplements the information contained in Add U.S. Privacy Policy.

It provides information required under the California Consumer Privacy Act of 2018 and as amended by the California Privacy Rights Act of 2020 (collectively, the “CCPA”), the Colorado Privacy Act of 2021 (the “CPA”), the Virginia Consumer Data Protection Act of 2021 (the “VCDPA”), the Utah Consumer Privacy Act of 2022 (the “UCPA”), the Connecticut Data Privacy Act of 2022 (“CDPA”), the Texas Data Privacy and Security Act (the “TDPSA”), and any and all regulations arising therefrom (collectively, “Applicable Laws”). Some portions of this Supplemental Policy apply only to consumers of particular states, and we have indicated where those portions are state-specific.

If you are unable to review or access this Supplemental Policy due to a disability, you may contact us at support_eu@gungho.jp to access this Supplemental Policy in an alternative format.

1. Definitions Specific to this Policy.

“Consumer” means a natural person who resides in California, Colorado, Connecticut, Virginia, Texas and Utah, and to whom we offer information, goods, or services.

*For purposes of this Supplemental Policy and subject to laws and regulations in each applicable state, the term “Consumer” may also include natural persons who reside in any of the above-described states and engage with us as part of business-to-business transactions, including, without limitation, transactions involving our customers (existing or potential), business partners, agencies and suppliers. In addition, the term “Consumer” may also include under certain circumstances job applicants, students, visitors to our website and claimants.

・“Personal Information” means information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular Consumer or household. Personal Information includes “personal data” as that term is defined in the Applicable Laws, including, without limitation, any information, including pseudonymous data and sensitive data, that is linked or reasonably linkable to an identified or identifiable individual. Personal Information also includes “Sensitive Personal Information,” as defined below.

・“Sensitive Personal Information” means Personal Information that reveals a Consumer’s: 1) Social security, driver’s license, state identification card, or passport number; 2) Account log-in, financial account number, debit card number, or credit card number in combination with any required security or access code, password, or credentials allowing access to the individual’s account; 3) Precise geolocation; 4) Racial or ethnic origin; 5) Religious beliefs; 6) Union membership; 7) Contents of email or text messages, unless we are the intended recipient; 8) Genetic data; 9) Biometric information used to uniquely identify the Consumer, 10) Health, mental or health diagnosis, sex life, or sexual orientation, (11) citizenship or immigration status and (12) Personal Information collected from a known child. Sensitive Personal Information includes “sensitive data” as that term is defined in the Applicable Laws.

・“Sell,” “Sale,” or “Sold” means selling, renting, releasing, disclosing, transferring or other communications of an individual’s Personal Information to a Third Party for money or other valuable consideration.

・“Share,” “Shared,” or “Sharing” means disclosing, transferring and other communications of an individual’s Personal Information to a Third Party for behavioral advertising purposes, whether or not for money or other valuable consideration.

・“Third Party” means a person or organization which is not a Consumer, Vendor, or an entity owned or controlled by us and as defined by the Applicable Laws.

・“Vendor” means a “service provider,” “contractor,” or “processor” which collects, stores, or otherwise handles data for us, as those terms are defined in the Applicable Laws.

These definitions apply, whether terms are capitalized or not. Other terms used in this Supplemental Policy may be defined under the Applicable Laws, and they shall have the meanings described in those statutes. If there are variations between such definitions in different laws, you will be covered by the definition that applies in your state.

2. The Personal Information We Collect and Sell, Share or Otherwise Disclose.

The chart below shows the categories of Personal Information we may collect; examples of Personal Information in each category; types of sources from which each category of Personal Information is collected; the business purposes for which each category of Personal Information is collected; and the types of Vendors or Third parties with whom that category of Personal Information is shared. As this chart shows, we may share or sell certain Personal Information to Third Parties or disclose certain Personal Information to Vendors for business purposes. Our collection of Personal Information will be limited to what is adequate, relevant, and reasonably necessary to achieve the purposes of collection described below.

Category of Personal Information: Unique Identifiers

Examples: Real name, signature, alias, address, unique personal identifier, online identifier, IP address, email address, account name, physical characteristics or description.

Sources from which this Personal Information is Collected:

・Directly from you via our website
・Direct communication with you
・Social media interaction with you
・Marketing agencies

Business Purposes for Collection:

・Provide you with goods and services
・Managing your preferences
・Customer service communications
・Other Promotions

Types of Vendors or Third Parties with whom this Personal Information is Shared, Sold or Disclosed:

・Disclosed:

Web site hosters
Event planners
Credit check firms

・Shared or Sold: None
Category of Personal Information: Contact and Financial Information

Examples: Name, address, telephone, email, bank account or any other financial information

Sources from which this Personal Information is Collected:

・Directly from you via our website
・Direct Communication with you
・Claims management providers

Business Purposes for Collection:

・Complete transactions
・Other services and discounts
・Process claims
・Prevent fraud

Types of Vendors or Third Parties with whom this Personal Information is Shared, Sold or Disclosed:

・Disclosed:

Payment processors
Mailing houses
Lenders

・Shared or Sold: None
Category of Personal Information: Characteristics of Protected Classifications

Examples: Age

Sources from which this Personal Information is Collected:

・Directly from you via our website or sign-up

Business Purposes for Collection:

・Comply with legal requirements
・Ensure eligibility for services (e.g., over 18 years old)
・Accommodate special needs (e.g., disability)

Types of Vendors or Third Parties with whom this Personal Information is Shared, Sold or Disclosed:

・Disclosed:

Service coordinators
Contractors
Marketing consultants

・Shared or Sold: None
Category of Personal Information: Commercial Information

Examples: Records of products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies

Sources from which this Personal Information is Collected:

・Directly from you via our website
・Direct communications with you
・Social media interaction with you
・Marketing agencies

Business Purposes for Collection:

・Provide you with goods and services
・Invite participation in surveys and feedback
・Customer service communications
・Improve promotions

Types of Vendors or Third Parties with whom this Personal Information is Shared, Sold or Disclosed:

・Disclosed:

Web hosters
Payment processors
Marketing consultants
Contractors

・Shared or Sold: None
Category of Personal Information: Internet or Other Electronic Activity

Examples: Browsing history, search history, and information regarding a consumer’s interaction with an internet website application, or advertisement

Sources from which this Personal Information is Collected:

・Directly from you via our website
・Direct communication with you
・Social media interaction with you
・Marketing agencies

Business Purposes for Collection:

・Provide you with goods and services
・Invite participation in surveys and feedback
・Customer service communications
・Improve promotions

Types of Vendors or Third Parties with whom this Personal Information is Shared, Sold or Disclosed:

・Disclosed:

Web hosters
Payment processors
Contractors

Shared or Sold: None
Category of Personal Information: Geolocation Data

Examples: Device location

Sources from which this Personal Information is Collected:

・From your digital device
・Direct communication with you
・Social media interaction with you

Business Purposes for Collection:

・Provide you with goods and services
・Customer service communications
・Improve promotions

Types of Vendors or Third Parties with whom this Personal Information is Shared, Sold or Disclosed:

・Disclosed:

Security providers

・Shared or Sold: None
Category of Personal Information: Inferences Drawn from Other Categories to Create a Profile

Examples: Profile reflecting preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes

Sources from which this Personal Information is Collected:

・Directly from you via our website
・Direct communication with you
・Social media interactions with you
・Marketing agencies

Business Purposes for Collection:

・Provide you with goods and services
・Customer service communications
・Improve promotions

Types of Vendors or Third Parties with whom this Personal Information is Shared, Sold or Disclosed:

・Disclosed:

Marketing consultants
Service providers

・Shared or Sold: None

3. Sensitive Personal Information We Collect and Disclose.

CATEGORY OF SENSITIVE PERSONAL INFORMATION
Account log-in, financial account, debit card number, plus an access code

SOURCES FROM WHICH THIS SENSITIVE PERSONAL INFORMATION IS COLLECTED
・Directly from you via our website

BUSINESS PURPOSES FOR COLLECTION
・Complete transactions
・Offer services and discounts
・Prevent fraud

TYPE OF VENDORS OR THIRD PARTIES WITH WHOM THIS SENSITIVE PERSONAL INFORMATION IS SHARED, SOLD OR DISCLOSED
・Disclosed: None
・Shared or Sold: None

CATEGORY OF SENSITIVE PERSONAL INFORMATION
Precise Geolocation

SOURCES FROM WHICH THIS SENSITIVE PERSONAL INFORMATION IS COLLECTED
・From your digital device

BUSINESS PURPOSES FOR COLLECTION
・Network security

DORS OR THIRD PARTIES WITH WHOM THIS SENSITIVE PERSONAL INFORMATION IS SHARED, SOLD OR DISCLOSED
・Disclosed:
- IT providers
- Security providers
・Shared or Sold: None

4. Retention of Data.

We intend to retain each category of Personal Information described above only for as long as necessary to fulfill the purpose for which it was collected, or a related and compatible purpose consistent with the average consumer’s expectation, and to comply with applicable laws and regulations. We consider the following criteria when determining how long to retain Personal Information: why we collected the Personal Information; the nature of the Personal Information; the sensitivity of the Personal Information; our legal obligations related to the Personal Information, and risks associated with retaining the Personal Information.

5. Your Rights to Your Personal Information.

Consumers have certain rights with respect to the collection and use of their personal information. Those rights vary by state. As required by the Applicable Laws, we provide detailed information below regarding the data subject rights available to consumers. Consumers can find more detail by referencing the Applicable Laws.

You have the right to submit requests related to the Personal Information we have collected about you. You may make such a request twice in a 12-month span. Please note, there are circumstances when we may not be able to comply with your request. For example, we may not be able to verify your request or we may find that providing a full response conflicts with other legal obligations or regulatory requirements. We will notify you if this is the case.

6. Right to Receive Information on Privacy Practices.

You have the right to receive the following information at or before the point of collection:

・The categories of Personal Information to be collected;
・The purposes for which the categories of Personal Information are collected or used;
・Whether or not that Personal Information is sold or shared with Third Parties or disclosed to Vendors;
・If the business collects Sensitive Personal Information, the categories of Sensitive Personal Information to be collected, the purposes for which it is collected or used, and whether that information is sold or shared; and
・The length of time the business intends to retain each category of Personal Information, or if that is not possible, the criteria used to determine that period.

We have provided such information in this Supplemental Policy, and you may request further information about our privacy practices by using the contact information provided below.

7. Right to Know and Right to Access.

You have the right to request a portable copy of certain information we have collected about you. You have the right to request:

・Specific pieces and categories of Personal Information we collected about you;
・The categories of sources from which Personal Information was collected;
・The purposes for which Personal Information was collected, shared, sold, or processed;
・The categories of Personal Information we shared, sold or disclosed; and
・The categories of Vendors or Third Parties with whom we shared, sold or disclosed Personal Information.

If you would like to make a request to know or to access a portable copy of your Personal Information, you can use the email address or phone number listed below.

8. Right to Delete.

You have the right to request that we delete certain Personal Information that we have collected. If you would like to make a request to delete your Personal Information, you can use the email address below.

9. Right to Correct.

You have a right to request that we correct any inaccurate Personal Information we may retain about you. If you would like to make a request to correct your Personal Information, you can email us support_eu@gungho.jp

10. Right to Opt-Out of the Sale and Sharing of Your Personal Information.

You have the right to opt-out of the sale and sharing of your Personal Information with Third Parties, and the right to opt out of the processing of Personal Information for targeted advertising purposes (or profiling in furtherance of a decision that produces a legal or similarly significant effect concerning the consumer), as defined in the Applicable Laws.

We sell or share Personal Information, or process Personal Information for targeted advertising purposes. In the past 12 months, we have sold or shared the categories of consumer personal information as listed in this Supplemental Policy. As a consumer, you have the right to opt-out of the sale and/or sharing of your Personal Information and of the processing of Personal Information for the purpose of targeted advertising. To submit an opt-out request, please use the email address or phone number listed below. We do not knowingly sell or share Personal Information of consumers under 16 years of age.

If you opt-out of the sale of your Personal Information, we will wait at least 12 months before asking you if we may sell or share your Personal Information. You have the right to opt-in to the sale of your Personal Information after you have opted out. If you would like to opt-in to the sale or sharing of your Personal Information, please email us at support_eu@gungho.jp. Opting-in is a two-step process in which you will first clearly request to opt-in, and then separately confirm that choice.

11. Right to Consent to or Limit the Use of Your Sensitive Personal Information.

You have the right to consent to the use of your Sensitive Personal information under Applicable Laws. Separately, you have the right to instruct us to limit the use and disclosure of your Sensitive Personal Information to only that which is necessary to perform the services or provide the goods reasonably expected by an average consumer or for specific business purposes defined by law. However, we do not use Sensitive Personal Information for purposes beyond those authorized by Applicable Laws, or beyond your consent. By accepting this Supplemental Policy pursuant to a statement by electronic or other means permitted under the Applicable Laws, you acknowledge and agree that you will be signifying your freely given, specific, informed, and unambiguous agreement to process your Personal Information (including Sensitive Personal Information) pursuant to this Supplemental Policy.

12. Right to Non-discrimination.

You have a right to exercise the above rights and we will not discriminate against you for exercising these rights. Moreover, we will not process Personal Information in violation of applicable state and federal antidiscrimination laws. Please note that a legitimate denial of a request to access, delete, or opt-out is not discriminatory, nor is charging a fee for excessive or repetitive requests.

13. Instructions to Exercise your Rights.

If you would like to exercise any of the rights described herein or make any of the data requests listed above, please contact us using one of following two methods: (a) at support_eu@gungho.jp. If you use the telephone number, you will be guided through a process that will allow you to submit a verifiable request, and the level of verification will depend on the request being submitted. If you use the email address, we may email you to request additional information from you to verify your request. You may designate an authorized agent to exercise your rights under the CCPA on your behalf. Such individual must have power of attorney, or be an authorized agent registered with the relevant Secretary of State. We will provide information in response to your request at least twice annually and free of charge, unless the request is manifestly unfounded, excessive, or repetitive.

14. Right to Appeal.

If you submit a request to exercise your data subject rights under this Supplemental Policy and it is denied, or if we fail to act on your request within the required period of time, you have the right to appeal that decision or failure to act, as applicable. If you choose to appeal, your request will move from HR to our Legal Department for review. If you would like to submit an appeal, please email support_eu@gungho.jp. Please state that your request is an “Appeal,” and describe the date and nature of your original request. Pursuant to the TDPSA, if we deny your appeal, you may submit a complaint with the Texas Office of the Attorney General at: Consumer Complaint Form | Office of the Attorney General (salesforce-sites.com).

15. Verification Process/Response to Requests.

When you submit a request to exercise your data subject rights, we may ask you to provide information that will enable us to verify your identity. If you designate an authorized agent to exercise your rights on your behalf, we may require that you or the authorized agent do the following:

・Verify your identity with us directly.
・Provide proof of your signed written permission for the authorized agent to submit a request on your behalf.

We may deny a request from an agent purportedly acting on your behalf if we request, and the agent does not submit, proof that he, she, or it has been authorized by you to act on your behalf.

We will authenticate and respond to your rights request within the applicable time periods set forth in the Applicable Laws, including, without limitation, within 45 days as required under the TDPSA (subject to an additional 45 day extension when reasonably necessary).

16. Personal Information of Minors.

We do not knowingly collect, store, process, Sell or Share information from minors under the age of eighteen (18) years except as required by applicable laws.

If we become aware or you or your parent/legal guardian identify to us or one our Third Party partners, that you are a minor under the minimum age of consent guidelines set by applicable laws, we will:

(a) Promptly obtain verifiable consent from your parent or legal guardian for the use your Personal Information, when required by applicable laws; and

(b) offer controls and choices to parents and legal guardians. For example, if your parent or legal guardian wishes to revoke their previously provided consent, we will provide them with an opportunity to review information collected from you or have that information deleted by contacting us via the process described in Section 13 (Instructions to Exercise Your Rights). If we become aware that you have provided us with Personal Information without verifiable consent as required by applicable law, we will delete any Personal Information we have collected, unless we have a legal obligation to keep it, and terminate your account and/or revert you to the age-appropriate experience, as applicable. If we make material changes to how we collect, store, use, Sell, Share or otherwise process Personal Information of minors under the minimum age of consent guidelines set by applicable laws, we will update this Policy accordingly and if applicable, notify such minor’s parents or legal guardians as required by applicable law.

17. Additional California Privacy Rights: Shine the Light Request.

California Civil Code Section § 1798.83 permits users of our website who are California residents to request certain information regarding our disclosure of Personal Information to other parties for their direct marketing purposes. To make such a request, please send an email to support_eu@gungho.jp with the subject “Shine the Light Request.”

18. Changes to Our Supplemental Policy.

We reserve the right to amend this Supplemental Policy at our discretion and at any time. When we make changes to this Supplemental Policy, we will post our updated notice online with a new “Revised on” date at the top of the page. We encourage you to review this Supplemental Policy regularly to ensure you are aware of any updates.

19. Contact Details.

If you have any questions about this Supplemental Policy, please contact us at: GungHo Support.

GungHo Online Entertainment, Inc.
Pacific Century Place Marunouchi, 1-11-1 Marunouchi, Chiyoda-ku,
Tokyo, 100-6221 Japan

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