Privacy Policy
This Privacy Policy applies to all of games, websites, and related services (hereafter collectively referred as the "Services") provided by GREMORY GAMES INC. (hereafter referred as "We", "GREMORY GAMES", and/or "GREMORY"). Your continued use of the Services after the effective date will be subject to new Privacy Policy. Please read the following to learn more about how we use your personal information.

We may periodically update this Privacy Policy by posting a new version on the website. If we make any material changes, we will notify you as required under applicable law, including by posting a notice in the Service prior to the changes becoming effective.

If you have questions about data protection, or if you have any requests for resolving issues with your personal data, we recommend you to primarily contact us through the support features within our games, or through the following address:

GREMORY GAMES INC.
support@gremorygames.com

1. Collected Data
The categories of personal data we collect depend on the Services you use, and the requirements of applicable law.

(a) Data directly provided from the users.
(i) Contact information, including but not limited to: Name, email address, and/or phone numbers
(ii) Player name or tag and password
(iii) Profile information, e.g. profile photo
(iv) Your messages to the Service, including but not limited to chat logs and/or player support tickets
(v) Other data you choose to give us. These data include, but are not limited to, data to identify a lost account or data you provide to participate in surveys or promotional programs.

(b) Data automatically collected from the Services.
(i) Data about your account and game progress, including in most cases an automatically created internal account ID
(ii) Your IP address and mobile device identifiers, e.g. your device or advertising ID
(iii) Data about your device, such as device name and operating system, browser type and language, internet service provider, and mobile carrier
(iv) Data we collect with cookies and similar technologies (see more below)
(v) Approximate location data, as derived from IP address
(vi) Precise geo-location data (GPS), with your consent
(vii) Data about your use of the Service, such as gameplay data and your interactions with other players inside the Service

(c) Data provided from the Third Parties.
We also use third-party partners, such as social networking services (SNS), data analytics providers and advertising networks to supplement information we have about you. This information includes:
(i) Data we receive if you link a third party tool with the Service, e.g. Facebook, LINE, Twitter, Google, etc.
(ii) Demographic data, such as to determine the coarse location of your IP address
(iii) Data to fight fraud, such as refund abuse in games or click fraud in advertising
(iv) Data from platforms that the games run on, such as to verify payment
Data for advertising and analytics purposes, so we can provide you a better Service
(v) Data that you have made available to us from a third party service (such as LINE, Google or Facebook) via your privacy settings
2. Disclosure of Personal Data with Third Parties
We disclose the personal data we collected with the Third Parties. The Third Parties that we disclose the personal data are business partners, i.e. contractors, service providers, other business partners, including but not limited to the following:
(a) Platform service providers.
(b) Cloud service providers.
(c) Data center contractors.
(d) Business operation support contractors.
(e) Developers.
(f) Shipping companies.
(g) Publishing companies.
(h) Service monitoring companies.
(i) Fraud monitoring companies.
(j) Payment and settlement companies.
(k) Auditing firms.

3. Use of Personal Data and Disclosure to Third Parties, Purpose of Data Processing
We use the collected personal data for the following purposes:

(a) Data directly provided from the users.
(i) Use of the services.
(ii) Improvement of service and usage.
(iii) Response to user inquiries and requests.
(iv) Prevention of fraud and abuses.
(v) Distribution of advertisements.

(b) Data automatically collected from the Services.
(i) Fulfillment of contractual obligations.
(ii) Maintaining contact information.

(c) Data provided from the Third Parties.
(i) Fulfillment of contractual obligations.
(ii) Maintaining contingency contact information.
(iii) Taxation.

4. Legal Basis to Use Persona data
We handle and use the collected personal data to the extent applicable to the followings:

(a) Fulfillment of contractual obligations: To fulfill our contractual obligations by and between us and the users, including but not limited to membership management, purchase of service/items, and response to user inquiries and requests.

(b) Legitimate interests: To use the collected personal data in order to conduct our business with legitimate reasons, including but not limited to website improvements and prevention of frauds and abuses.

(c) Compliance with legal obligations: To use the collected personal data in order to comply with the legal requirements, including but not limited to judicial and governmental orders and tax procedures.

We may also ask consent for using your personal data. Consents will be obtained by specific methods, including but not limited to checkboxes with the tagline "I agree with the processing of personal data." This consent will be a legal base for our processing your personal data. You can withdraw your consent anytime.

Upon your consent when it is regulatory required, we use cookies and other similar methods to compile information about the usage of our website. When you visit our websites,

5. Retention
We retain your persona data only as long as we are entitled or required under applicable laws or it is necessary in relation to the purposes. This is usually up to 7 years after you close your account, or your last contact in case you do not own an account. Upon the lapse of this period, we will either delete or anonymize your personal data.

6. User's Rights
In accordance with the GDPR, where you have given your consent to process your personal data, you may withdraw it at any time. You also have the right to object your personal data being processed for direct marketing purposes at any time.

Furthermore, provided that the applicable statutory conditions are met, you have the legal rights to request us the followings:
- Information on what personal data we have about you
- Correction of your personal data if inaccurate or incomplete
- Erasure of your personal data if we have no lawful ground to process them
- Suspension of using your personal data during our processing method is being contested
- Obtaining your personal data in computer-readable format

7. Safety Control Measures
We take safety and confidentiality measures for the collected personal data.
We take technical, administrative and physical security measures to prevent personal data from unauthorized accesses and improper uses.
We periodically conduct reviews of the security measures to consider implementing new technologies and/or methodologies.


8. Inquiry
For any inquiries or requests concerning your personal data, including but not limited to disclose, correct, stop the use of, delete your personal data, please contact support@gremorygames.com


9. Cookies
In order to provide improved services to the users, we may use cookies on our websites. These cookies will not breach your privacy. Websites where cookies are used will clearly indicate in advance the use intended for each cookie. Depending on the browser you use, you may be able to change its settings to disallow and/or inactivate cookies. However, disabling cookies may prevent you from using some or any of the services on the website.

※This Privacy Policy was revised on September 02, 2020
※This privacy policy will be revised and enhanced without prior notice.
※This Privacy Policy was revised on September 10, 2020