SHUEISHA GAMES Privacy Policy

SHUEISHA GAMES Inc. (hereinafter “Our Company”), while establishing a “Basic Policy of SHUEISHA GAMES on How to Treat Personal Information” to protect the privacy of those who use the websites operated by Our Company, announces this privacy policy (hereinafter the “Privacy Policy”) on how Our Company processes customers’ personal data including customers’ personal information. Definitions of the terms used in this guideline are as follows:

■ “Personal Information”
“Personal Information” shall have the same meaning as that of “personal information” defined in the Japanese “Act on the Protection of Personal Information” (Act No. 57 of May 30, 2003, amended on September 3, 2015, hereinafter the “APPI”), i.e., information containing a name, address etc., through which a specific individual can be identified, and information containing an individual identification code, including the license number of a driver’s license, and face recognition data. Information, through which a specific individual cannot be identified, but that can be easily collated with other information and thereby used to identify such individual, shall also be included in Personal Information.

■ “Information Related to Personal Information”
“Information Related to Personal Information” shall mean information related to a certain individual, including access log information associated with internet use, that, while not sufficient to identify a specific individual, is distinctive in that one can recognize it as “information related to a certain individual.” This includes information concerning information communication equipment (e.g., an identifier, including an identification code, unique to each equipment and location data), the browsing history of webpages, etc. available through a cookie identifier, etc., or an email address or account ID, through which alone a specific individual cannot be identified.

■ “Personal Data”
“Personal Data” shall be a concept regarding customers’ privacy and the collective term for both “Personal Information” and “Information Related to Personal Information.”

■ “Statistical Information”
“Statistical Information” shall mean Information Related to Personal Information modified for statistical purposes, so that the information can no longer be associated with a specific individual.

1. Collection of Personal Data

Our Company collects the following Personal Data in any of the following cases:

1. Input by a customer through information communication equipment (the Personal Data the customer provides, such as email address, name, telephone number, etc.);
2. Submission of documents, etc. directly by a customer (the Personal Data contained in such documents);
3. Automated collection with the help of cookies in association with a customer’s use and/or browsing of services, content, goods, advertisements, etc. (access logs containing data such as date and time Our Company’s website is accessed, number of accesses, IP address and location, type of OS and browser used, referrer URL, etc.);
4. Provision by a third party to whom the customer has given consent (the Personal Data provided by the third party); and
5. Other lawful collection.

2. Purposes of Processing Personal Information

The purposes for which Our Company processes Personal Information are as follows:

1. Provide content and services, recommended information, and advertisements that meet our customers’ needs, including research and analysis of customer behavior for this purpose.
2. Deliver or charge for products, services and prizes ordered or applied for, award points to our customers, confirm the customer’s identity and other information, and contact our customers in this regard, including confirmation with financial institutions and credit card companies for payment procedures.
3. Communicate the results, etc., to customers who participate in surveys, events, etc., and to customers who enter sweepstakes and lottery sales, etc.
4. Inform our customers about products, prizes, events, and other services.
5. Improve and enhance our services, and develop new services, including related research and analysis of customer behavior.
6. Respond to inquiries from customers.
7. Prevent and respond to fraudulent activities, etc.
8. Provide information on products, prizes, events, and other services from partner companies, etc., deliver products and prizes provided by such companies, etc., and send questionnaires, etc.
9. Notify our customers of the establishment, change, or abolition of our terms and conditions, etc.

Should there be any specific provision as to a purpose of use for certain Personal Information, Our Company will process such Personal Information in accordance with such provision. The same shall apply to cases where Our Company receives Personal Information from a third party to whom the customer has given consent, provided that there is any specific provision regarding the purpose of use.

Customers can choose whether to provide Personal Information to Our Company at their own discretion, provided they understand that choosing not to provide information may prevent them from using the services, etc. Our Company provides.

3. Processing of Information Related to Personal Information (Access Logs, etc.)

Purposes of Processing Information Related to Personal Information.
Our Company will use Information Related to Personal Information, including access logs, for the purposes described below. Our Company may use Information Related to Personal Information in connection with Personal Information Our Company collects. In such an event, Our Company will limit the purpose to the “Purposes of Processing Personal Information” prescribed in this Privacy Policy.

1. Identify customers and improve their convenience.
2. Provide the best possible services and content, etc. for our customers.
3. Improve service quality.
4. Provide behavioral targeting advertising.

Details of Information Related to Personal Information, Including Access Logs, etc.
Details of Information Related to Personal Information, including access logs, etc., that Our Company collects, are as follows:

1. Collection of Access Logs
   When a customer accesses the website operated by Our Company, Our Company collects certain information as access log and stores the same for a certain period of time. The access log includes the following information: date and time of access, number of accesses, IP address, type of browser used, cookies, etc. This information does not include information through which a certain individual can be identified, e.g., name or address of the customer. Our Company does not intend to identify customers through this information. Our Company uses this information to improve its services.
2. Use of Cookies
   Cookies are small data files transferred and received between a web server and the customer’s browser when a customer uses a website. When a customer sets their personal computer or mobile phone to accept (allow) cookies, cookies are stored in a certain area of the used device. If a customer accesses the same website again, the website operator can change the website’s display based on the information available through the cookie, depending on each customer. While Our Company can identify a customer’s browser through a cookie, Our Company cannot identify a customer solely based on a cookie. Some of the websites operated by Our Company use cookies.
3. Cookie Settings
   Customers can change their browser settings so that they reject cookies, or a warning appears when accepting cookies. For more information, customers should refer to the “Help” menu of their browser.
4. Third Party Cookies
   On the website Our Company operates, third parties that are partner or sponsor companies of Our Company may, with Our Company’s permission, send, receive and use their cookies in connection with customers for the purposes of, for example, developing new services and improving existing services, including displaying personalized content and advertisements the customers view based on attributes that do not include the customers Personal Information, displaying advertisements of Our Company on various websites on the internet, and analyzing the customers’ use of services of Our Company (including measuring the effectiveness of advertisements and content posted on the website operated by Our Company). Cookie information collected through such processes is stored not on Our Company’s servers, but on those of partner companies and third parties, and treated in accordance with the applicable privacy policies of those companies. Customers may disable the use of such cookie information retained by partner companies or third parties by accessing the opt-out (disable) pages of those companies by themselves.
5. Behavioral Targeting Advertisements
   Behavioral targeting advertisements categorize customers according to their interests and preferences based on their behavioral history, and display relevant internet advertisements depending on such categorization. Part of the advertisements displayed on the websites operated by Our Company are distributed by partners of Our Company. Some of these advertisements use cookies, etc. for behavioral targeting. To opt-out of (disable) behavioral targeting advertisements by partner companies, customers should visit the websites of such partner companies and take the necessary steps.
6. Details of Cookies
   For information about the cookies used on this website, please see below.
   

4. Joint Use of Personal Data

Our Company and group companies of Our Company may jointly use Personal Information collected by them within Shueisha Group. For details on joint use, please read below:

1. Information Subject to Joint Use
   - All information related to customers’ Personal Information Our Company has collected.
2. Joint Users:
   - Shueisha and its group companies. For a list of Shueisha’s group companies, please see here.
3. Purposes of Processing
   - As stated in the “Purposes of Processing Personal Information” in the “SHUEISHA Privacy Policy.”
4. Name of Person in Charge of Management of Personal Information Subject to Joint Use
   - Shueisha Inc.

5. Provision of Personal Information to Contractors

Our Company may commission the processing of Personal Information to a third party located in Japan to the extent necessary for the prescribed purposes of processing. Our Company will limit the contractors for such commission to those Our Company deems reliable, and Our Company will, in accordance with Our Company’s Personal Information Guideline, take the necessary measures to ensure that customers’ Personal Information is properly protected by such contractors. Our Company may commission a foreign third party and provide Personal Information to such third party within the scope permitted by the APPI. Thus, for example, Our Company must ensure that such third party has established a system necessary to continuously comply with the corresponding APPI rules.

6. Provision of Personal Information to a Third Party

Our Company will not provide collected Personal Information to a third party without obtaining the customer’s prior consent, except in any of the following cases:

1. Cases based on laws and regulations, including inquiries pursuant to Criminal Procedure Law;
2. Cases in which it is necessary to protect human life, bodily integrity, or property, and it is difficult to obtain the customer’s consent;
3. Cases in which there is a special need to improve public wellbeing or promote healthy child development;
4. Cases in which the provision of Personal Information is requested by public authorities, such as national or local government organs, and Our Company deems it appropriate to cooperate with such authorities.

Our Company may provide collected Personal Information to a third party as anonymously processed information in accordance with laws and regulations, after properly processing the same so that it cannot be used to identify a specific individual , or as Statistical Information, by which a specific individual cannot be identified.

When Our Company provides Personal Information to a third party with the customers’ prior consent, Our Company will require the recipients of the Personal Information in writing to appropriately and securely manage said Personal Information.

7. Management, etc. of Personal Information

The websites operated by Our Company adopt high security server software (a digital certificate for the web server) called SSL (Secure Sockets Layer), which is applicable when a customer inputs Personal Information. SSL is the world’s most common security system, encrypting Personal Information so that a third party cannot access it. By adopting this technology, Our Company seeks to establish a secure website that is protected from the risks associated with the internet, including wiretapping, tampering, and ID theft of Personal Information.

8. Disclosure, Correction, etc. of Personal Information

Our Company will respond as soon as reasonably possible to customers’ requests for disclosure, correction, etc. of their own Personal Information, provided that such requests are in accordance with the application procedure prescribed by Our Company and that, in the case of a request for disclosure, Our Company has received the handling charge for such procedure. However, Our Company may not meet such request if disclosure would seriously interfere with Our Company’s business or infringe on the rights of a third party. Please understand and agree in advance that membership services provided by the website operated by Our Company and the purchase of goods cannot be provided to a customer whose Personal Information is deleted.

９. Links to External Websites

The website operated by Our Company may include links to external websites. In no event shall Our Company be responsible or liable for the handling or protection of Personal Information, or the content on external websites. In case of any questions or concerns, customers should contact the relevant websites directly.

10. Amendment of the Privacy Policy

Our Company may amend all or part of this Privacy Policy from time to time to reflect changes in the business of Our Company and/or amendments to laws and regulations concerning the protection of Personal Information. In the event of an amendment, Our Company will announce such amendment in advance on this website for a certain period of time.

11. Inquiries on Personal Information

If a customer has any inquiries concerning the treatment of Personal Information by Our Company, please contact us here. Depending on the nature of the inquiry, Our Company may need to confirm the identity of the person who made the inquiry before responding.

Our Company may introduce or send services, goods, or surveys by direct mail, facsimile, or email, etc., based on the Personal Information and/or Information Related to Personal Information Our Company possesses. If you wish to unsubscribe, please do so here.

12. [Additional Information for EEA/UK Individuals]

The following information also applies:
The protection of your Personal Data (within the scope of the definition of Art. 4 GDPR) is important to us. Our Company therefore adheres to the applicable legal provisions for the protection, lawful handling and confidentiality of Personal Data, as well as for data security, in particular the European Union General Data Protection Regulation (“GDPR”) and the UK GDPR.

By continuing to use the websites and services, etc. provided by Our Company, you acknowledge that your Personal Data will be processed based on this Privacy Policy. If you do not agree with the processing of your Personal Data based on this Privacy Policy, you will not be able to use the websites and services, etc. offered by Our Company.

Data Controller/Representative
The controller for the processing of your personal data is:
SHUEISHA GAMES Inc.
PMO Jimbocho 10F, 2-10-4 Kanda Jimbocho, Chiyoda-ku, Tokyo 101-0051, Japan

In the case of joint processing of Personal Data in accordance with Section 4 of this Privacy Policy, Our Company and the relevant group companies of Our Company act as joint controllers.

The controller's designated representative in the European Union and United Kingdom is:

Data Protection Representative Limited

[EU] DataRep, 72 rue de Lessard, Rouen, 76100, France
datarequest@datarep.com
(please insert “SHUEISHA GAMES” in the subject line)

[UK] DataRep, 107-111 Fleet Street, London, EC4A 2AB, United Kingdom
datarequest@datarep.com
(please insert “SHUEISHA GAMES” in the subject line)

Purposes and Legal Basis for the Processing of your Personal Data
Our Company processes your Personal Data as provided for in Section 1 of this Privacy Policy for the following purposes and based on the following legal basis:

Indirect Collection of Personal Data
Our company may collect Personal Data (such as user name, email address, etc.) from partner companies of Our Company listed below, if you use or link your account with these partner companies when registering for, or using Our Company’s website or services. The processing of Personal Data by our partner companies is governed by their respective privacy policies and is beyond our responsibility.

Partner companies: X Corp., Google LLC, Valve Corporation

Recipients of Personal Data
In order to operate its website, and to offer its services, Our Company may share your Personal Data with its group companies and service providers (marketing companies, IT service providers, etc.). Our Company may also transfer your Personal Data to external third parties to the extent necessary to fulfill the purposes for the processing of Personal Data stated above, or public authorities to the extent required by laws and regulations. Please see Sections 4 through 6 above. Your Personal Data will not be transferred to any other third parties for their own purposes without your consent.

Transfer of Personal Data to Third Countries
Our Company may transfer your Personal Data to group companies, service providers, and other third parties in third countries other than Japan, an EEA country, or the UK. In each case, Our Company will ensure that such transfer takes place on the basis of an adequacy decision by the European Commission or the UK Government, or, in the absence thereof, on the basis of appropriate safeguards (standard data protection clauses, etc.), including enforceable rights and legal remedies for individuals. With regard to data transfers to Japan, the European Commission has recognized Japan as providing an adequate level of data protection, meaning that Personal Data can be transferred from the EEA to Japan without requiring additional safeguards.

Cookies/Google Analytics
Our Company’s website uses cookies and similar technologies to collect and store information (for details, please see Section 3 above), including for the functions of the web analysis service Google Analytics. The provider of Google Analytics is Google Inc., 1600 Amphitheatre Parkway, Mountain View, CA 94043, United States. Cookies enable the customers’ use of the website (browsing history, purchase history, etc.) to be analyzed in order to improve its performance and functionality. The information generated in this way is transferred to the servers of Google Analytics, which may be located outside Japan, the EEA, or the UK (e.g., in the United States). Google processes your Personal Data on Our Company’s behalf for the purposes outlined in this Privacy Policy. Google may also use data in an aggregated and anonymized form for its own purposes, as outlined in Google’s Privacy Policy. In order to enhance our customers’ privacy, Our Company has entered into a data processing agreement with Google, and has configured Google Analytics to make use of IP anonymization, and to behave based on your consent choices.

Except for technically required cookies (essential cookies), which are used to display Our Company’s website in a secure and convenient way for our customers, and are thus necessary for the purpose of data security and prevention of misuse (the legal basis is our legitimate interest in this regard), cookies will only be enabled if you voluntarily give your explicit consent through our cookie consent mechanism implemented as a pop-up window on our website. You can manage your cookie preferences at any time. In addition, you may also prevent cookies from being stored by selecting the corresponding settings in your browser.

For information about the cookies used on this website, please see section 3.

Storage Period
Our Company only stores Personal Data for as long as necessary to fulfill the purposes for the processing of Personal Data stated above, and its contractual and legal obligations. When customers’ Personal Data is no longer needed, Our Company will delete it from its systems and records, or make it anonymous, so that it can no longer be used to identify a customer.

Rights Regarding Personal Data
Customers have the right to be informed about the Personal Data processed by Our Company and to access such data, to have inaccurate or incomplete data rectified, and to have data deleted (“right to be forgotten”). In addition, customers are entitled to request restriction of processing of their Personal Data under certain circumstances, to receive such data in a structured, commonly used and machine-readable format (“data portability”), and to object to the processing of such data at any time, if there are grounds for doing so relating to their particular situation. Customers also have the right not to be subject to a decision based solely on automated processing, including profiling.

Where the processing of Personal Data is based on consent, such consent may be withdrawn at any time with effect for the future.

If you have any questions regarding your Personal Data or wish to exercise any of the rights stated above, please click here and enter your request regarding personal data.

You may also contact our Data Protection Officer:
SHUEISHA GAMES Inc.
PMO Jimbocho 10F, 2-10-4 Kanda Jimbocho, Chiyoda-ku, Tokyo 101-0051, Japan
mail: dpo@shueisha-games.com

When making a request, please include information on the Personal Data concerned, the reason for your request, and how you want Our Company to address your request.

Right to Lodge a Complaint with a Supervisory Authority
You have the right to lodge a complaint with a competent data protection supervisory authority, in particular in the country of your habitual residence, place of work, or place of the alleged infringement, if you believe that our processing of your Personal Data infringes the GDPR/UK-GDPR.

Data Security
Our Company implements appropriate technical and organizational measures to protect your Personal Data from unauthorized access, alteration, disclosure, or destruction (please refer to Section 7 above). However, no method of transmission over the internet or electronic storage is 100% secure.

History of the revisions:
Dated: 08/08/2025
Revised: 19/08/2025