Privacy Policy

Introduction

We at NextNinja Co., Ltd. value our users’ privacy and abide by global policies that govern the need to disclose information regarding personal data that is collected by our services, including but not limited to our mobile app, customer support, community practices, and any other services affiliated with “Grand Summoners”. This Privacy Policy covers what user information is collected, stored, and utilized by our services, and what rights you as a user have in accessing and modifying said data. We reserve the right to improve and revise the contents of this Privacy Policy based on, among other things, an amendment of the law, a change in our business or a user request.

Should any changes occur to the Privacy Policy, you will be notified in advance via an in-game announcement and asked to read, acknowledge, and re-confirm your acceptance of these alterations.

Where applicable, we will comply with the following regional protocols when processing personal data collected by the Services.

USA: The California Consumer Privacy Act of 2018 (CCPA) and the Children's Online Privacy Protection Act (COPPA).

European Union (EU): The General Data Protection Regulation (GDPR).

Japan: Act on the Protection of Personal Information (Act No. 57 of 2003) (Personal Information Protection Law).

In addition, by agreeing to this Privacy Policy, you consent to your data being accessed and processed by our staff and other relevant personnel, including engineers and customer service representatives.

0.1 Collected Personal Data (directly or via third-party services)

We collect any personal data that may be required to identify the user, including but not limited to: username ID, email address, mailing address, telephone number, and any other types of information you may choose to provide.

(1) Types of Collected Information

a. Account Registration Information: Upon registration, you will be required to create a user account for your playthrough. All gameplay save data, progress, purchases, and other in-game activities will be associated with this username. The app’s service is usable at this stage, and no additional information is required to play the fundamentals of the platform. However, in order to fully access all available in-game selections, you may opt to provide us with any additional required personal information. This service is entirely optional, and any information provided by you will fall under this Privacy Policy collection method.




b. Date of Birth: Our in-game services do not request users to provide a date of birth prior to use. Users who download and play the game are responsible for providing accurate information regarding their self-reported age via Google Play or the Apple Store. Should any issue arise, this self-reported date of birth will be used as a basis for evaluation and judgment.




c. Email Address, Mail Address, or Telephone Number: In certain circumstances and with your full consent, we may collect additional information such as your phone number or email address. This data will be retained and stored with your consent.




d. In-Game User Content: These include chosen nicknames, chat data, and relevant information generated by users themselves. Such data is collected for the purposes of providing user-communicative options for all players.




e. Service Information: When communicating to report any technical trouble or seeking help from customer support, any required information you provide to resolve the issue at hand will be stored and used to ensure both the enhancement and delivery of optimal service.




f. Surveys: Should any surveys be conducted, inputted data will be stored and strictly used to improve the app’s functionality and service.F




g. Advertising: In order to gauge the efficacy of our advertising practices, we retain an Advertising ID for specific advertisements and device information tied to your profile. These are utilized strictly for marketing purposes on the basis of reasonable business interest in evaluating ad performance. Consequently, we employ third party network advertisers and analytics service providers in order to accomplish this task. For more information regarding third-party systems and sponsorship, please refer to the “Who Can Access Your Personal Data” section.




h. Participation in Events, Sweepstakes, and Giveaways: If you choose to participate in any events, sweepstakes, and/or giveaways in our service, we will require your name, user ID, nickname, email address, telephone number, and country/region in order to process your entry. If you win a prize, an announcement containing your ID and online nickname may be viewable for public access. Other information provided, however, will remain strictly confidential. If you participate in any of these services but do not win, your user ID and nickname will not be announced in any form on our platforms.




i. Third-Party Social Media Account Information, if Connected: If you choose to connect your account to any third-party social media service, we may use the username of your social media account with your consent in order to provide you with our service.




j. Sensitive Personal Information (SPI): These potentially include information pertaining to your real identity including name, physical addresses, and telephone numbers. If you choose to provide our service with any SPI, please be aware that aside from business transactions, all collected data will be processed within the confines of our Privacy Policy.

(2) Data Collected for System Functionality

Using service providers and other technology, we automatically collect data related to your access and use of the Services. Collected data includes but is not limited to IP addresses, cookies, web beacons, and embedded scripts. Collected information and collection methods are outlined below.

a. Cookies, IP addresses, and other related technologies

Collecting cookies allows us to determine how users are interacting with our websites (viewed pages, frequency of use, etc.). We use this information for the following purposes:

1. To provide a better user experience by reducing load times.

2. To provide users with advertisements that fit their preferences as determined by their personal data.

3. To perform analysis with the goal of improving user satisfaction based on what pages you view, what page referred you to our website, what links you click, etc.

4. To collect technical information linked to your access to the Services, including device software, operating systems and other similar technologies.

In addition to cookies, generated log file information may be collected upon visiting our website. This information includes:

i. Internet Protocol (“IP”) address: The unique address assigned to each device for connecting via a network.

ii. Device Information: The operating system, software and other technical information of the device used to access the Services.

iii. Referral and Exit URLs: Which URLs refer you to the Services, and which URLs are accessed when leaving.

Cookies will not be linked to any personal data you provide. Cookies may be shared with third-party contractors to personalize the Services, secure systems from fraud and evaluate the efficacy of our platform.

b. Web Beacons

Web Beacons (otherwise known as pixel tags, image tags, clear GIFs or web bugs) refer to code used to collect advertising data. Web beacons are used to monitor user browsing status, navigation behavior, advertising efficacy and email distribution.

c. Embedded Scripts

Embedded scripts are codes used to analyze your interactions with our platform, such as the links you click and your browsing patterns. These programming codes are only temporarily active and are downloaded to your device when using the Services. Embedded scripts may be used by third-party contractors.

d. Bugs, Errors, and Other Data Regarding Crashes and Diagnosis

If our app crashes or services are not functioning properly, information may be collected in order to circumvent such errors. Such data can range from in-game specifics (including user ID and current active version) in addition to device information (device model, memory size, graphics card details, etc.). All data collected in this regard is geared towards improving our business through crash diagnostics and subsequent patches.

e. Malicious Content

Information including user nicknames, chat logs, and in-game user communicative data is collected to ensure the safety of all users operating under our services. Malicious content that may potentially jeopardize user safety is swiftly dealt with following collection. Such information may also include actions that violate our Terms of Service, including the use of malicious words directed towards other users.

0.2 Reasons for Collecting Personal Data

In order to provide the Services, the required personal data outlined in this Privacy Policy must be processed. We comply with all applicable laws governing the handling and processing of personal data. On the basis that consent is obtained from the user (GDPR Article 6 Section 1a), collected personal data will be used for the purposes outlined below. Where user consent is not obtained, we may process your personal data if one of the following applies: (1) processing is necessary for the performance of a contract to which a user is party or in order to take steps at the user’s request prior to entering into a contract (GDPR Article 6 Section 1b); (2) processing is necessary for compliance with a legal obligation to which we are subject (GDPR Article 6 Section 1c); (3) processing is necessary in order to protect the vital interests of the user or of another natural person (GDPR Article 6 Section 1d); (4) processing is necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in the controller (GDPR Article 6 Section 1e); or (5) processing is necessary for the purposes of the legitimate interests pursued by us or by a third party, except where such interests are overridden by the user’s interests or fundamental rights and freedoms which require protection of personal data, in particular where the user is a child (GDPR Article 6 Section 1f). The legitimate interests pursued by us or a third party as outlined in No. 5 above include the improvement of our services, the bolstering of our security and marketing purposes.

1. To grant or restrict your access to the Services.

2. To upgrade and manage the Services, fixing bugs and errors, ensuring security and creating backups, for purposes of providing the Services.

3. To authenticate user identity when required.

4. To ensure the user’s safety and security.

5. To upgrade and develop the Services as requested by our players to enhance user experience, including additions and improvements to any in-app features.

6. Monitor and communicate with other users to address any violations.

7. Analyze obtained information to upgrade and manage our services, fix bugs and errors, ensure security, protect from fraud, and create potential archives and backups.

8. Authenticate a user’s identity when required.

9. Abide by any legal duties that may require user data authentication to ensure the safety and security of the platform and all its users.

10. Upgrade and develop our services as requested by our players to enhance user experience, including additions and improvements to any in-app features.

11. Monitor and track your use of our website to filter out any bots and enhance our platforms and services.

12. To ensure that we enforce our legal rights and defenses in the event of a legal dispute between us and a user.

In order to process the data, we may employ the use of third-party services.

If data is collected other than what is outlined in “Types of Collected Personal Data” or if we alter the data processing methods, the user will be notified and asked to consent to the new terms and conditions.

User consent regarding the processing of personal data may be rescinded at any time. This rescission will not have any effect on the legality of data processing based on prior consent.

0.3 Who Can Access Your Personal Data

In addition to our service teams, the following third parties may also access personal data you provide to us. By reading and agreeing to this Privacy Policy, you acknowledge that your personal data may be shared with the following third parties.

1. Other Users of Our Services

In-game, the user has options to personalize their account and communicate with other players via service options including battles. Users acknowledge that any information they post in these public areas may potentially be viewed by other players of our service. We urge players not to disclose any personal privacy information in such publicly viewable areas to ensure their safety.

2. Lawful Authorities

Personal data provided by users may be shared with any relevant competent authorities upon request. When deemed necessary (e.g., in the interest of protecting the Services and our users), some of your personal data may be disclosed to such authorities. This may include information that identifies your device (e.g., IP addresses) and your usage of the Services.

Furthermore, we have the right to share any personal data provided by users with such authorities to identify you and undertake legal action against you in the case of:

i. A violation of any agreements between us, including (but not limited to) this Privacy Policy and the Terms of Service.

ii. Your violation of any third parties' rights and/or interests.

iii. When such information is deemed necessary as a preventative measure against illegal activities, such as fraud and cyber attacks.

3. Third-Party Contractors

To provide the Services, we work with multiple third-party service providers. Personal data may be shared with these third-party contractors in a format that does not identify the user. Under no circumstances is personal data sold to such third-party contractors. Furthermore, certain third-party service providers are strictly prohibited from processing any personal data provided, including but not limited to accessing, storing or disclosing the data.

Accordingly, all data provided is limited to what is deemed necessary to provide the Services. Third-parties may include:

i. Social networks that are affiliated with our services via login or consent to content-sharing.

ii. Subcontractors (including but not limited to IT systems providers, IT contractors and information communication service providers).

iii. Payment service providers which aid us in processing payments made through in-app purchases, including the recording of transaction histories. Payment disputes and other issues may be resolved through this stored data. Please note that all payment transactions processed (including credit card number and/or security code) are done so through these service providers. We only retain information regarding the payment transaction date, costs, applied currency, and the purchased item(s).

iV. Advertising service providers that assist in distributing and targeting users for optimized advertisements and analyzing their performance and success rates.

V. Giveaways and Sweepstakes services may be utilized to deliver contests. Users who enter these giveaways do so with the knowledge that any personal data provided, including names and addresses, are stored and processed for the purposes of the promotion. Sponsors of these promotions may use your name or its likeness for advertising purposes and in cases where the user wins the sweepstake.

Vi. Logistics services that are employed to deliver any physical prizes won by our users in the aforementioned sweepstakes and other affiliated promotions.

Vii. Other third-party contractors that may be employed for the sake of delivering our services.

Please note that there may be circumstances where the user will have to directly communicate with third-parties should they wish to withdraw their services following consent. We ensure that any third-party information collection is only done following agreement by the user, either via updates to this Privacy Policy or other viewable notifications. In certain instances, however, if a user consents to a third-party service via our platform, communication with such contractors may be required to end the service. Furthermore, users must refer to the privacy policies of these third-party services to access the full scope of their data processing, storing, and utilization practices.

0.4 Advertisements

By consenting to this Privacy Policy, you acknowledge that we may collect an

To gauge and analyze advertisement appeal.

To conduct marketing activities.

Advertisements may be delivered directly by our services or by third-party contractors. In-game options allow you to opt out of participating in advertising analytics, such as by disabling push notifications that ask users to participate in surveys. Furthermore, users may withdraw at any time from having their personal data processed for advertising purposes.

On no account will our service collect the data of minors for advertising and marketing purposes. If it comes to our knowledge that a person not of legal age is engaging with our service, we will not deliver targeted advertising. For further detail, please refer to the “Regarding Age Limits and Restrictions” section of this Privacy Policy.

0.5 Personal Data Retention

All personal data collected by our systems will be stored as long as the user's account remains active. Personal data will be deleted upon user request or when stipulated by law.

If a user requests that use of their personal data be stopped, the data will continue to be stored so long as no applicable laws are violated.

Should any legal obligations or issues arise, such data may be utilized in accordance with an agreement between you and us. Upon account termination, your data and information will be stored and processed for the purpose of the previously outlined business practices in alignment with regional storage and retention period laws. All personal data will be anonymized, blocked, or erased once this period expire.

0.6 User Rights Regarding Collected Personal Data

All users may request, via writing, an electronic copy of their stored personal data.

For security purposes, in order to process these requests, the user will be asked to provide relevant information to verify their identity and link it back to their account. In addition, users may request a modification or deletion of their stored personal data, with the acknowledgment that this decision will have an impact on their user experience.

For further information and clarification regarding users in Europe and California, please refer to Section 0.6a and the "California Consumer Rights According to the CCPA" section below, which address the privacy legislation found in the GDPR and CCPA, respectively.

0.6a GDPR Compliance

In accordance with the GDPR, the user has the following rights:

1. The Right to Access

You have the right to gain free access to any personal data, as outlined in the GDPR. All users may request, via writing, an electronic copy of their stored personal data.

Under no circumstances will the Services sell the information of minors under the age of 16 (or corresponding relevant age in their country of residence).

2. The Right To Rectification

We work to ensure that all processed personal data is accurate when you engage with our various services.

However, in the event that any stored personal data is inaccurate or out of date, you have the right to rectify this information in accordance with Article 16 of the GDPR ("Right to Rectification").

Any updates to user information can be done via the Player Info on Menus tab found in the Services.

Furthermore, if the user submits a request via email, we will provide support to ensure the swift modification of personal data.

3. The Right To Erasure

You have the right to request the deletion of any personal information collected and stored by the Services, as outlined in Article 17 of the GDPR ("Right to be Forgotten").

Data deletion may also be requested on legal grounds.

In either case, please contact us using the contact information provided in the "Contact Address" section of this document to request the deletion of personal data.

4. The Right to Object

In accordance with Article 21 of the GDPR (“Right to Object”) and similar applicable laws in serviced countries, you have the right to any data processing performed as a result of using the Services. If a user voices an objection, data will cease to be processed unless there are legitimate grounds for doing so. Furthermore, as outlined in Article 21 Section 2 of the GDPR, you have the right to object to having your personal data processed for direct marketing purposes as outlined in the GDPR.

5. The Right to Restriction of Processing

In accordance with Article 18 of the GDPR ("Right to Restriction of Processing") or other applicable laws in the user's country of residence, you have the right to restrict the processing of your personal data where one of the following applies:

a. the accuracy of the personal data is contested by the user ,for a period enabling us to verify the accuracy of the personal data; In this instance, all processing will cease until the information is rectified by our service.

b. the processing is unlawful but the user requests a restriction on processing instead of deletion of the data;

c. we no longer have a need for the personal data, but the user requests access to the personal data for the purpose of exercising rights to make a legal claim; or

d. the user has objected to the processing of their personal data pursuant to Article 21 ("Right to Object") where it has not been verified whether the legal grounds of our position take priority over the user’s claims.

6.The Right to Data Portability

In accordance with Article 20 of the GDPR ("Right to Data Portability") and any other applicable laws in a user's country of residence, you have the right to receive stored personal data in a structured and commonly used machine-readable format. In addition, in accordance with the GDPR, you have the right to transmit this data to another administrator without our interference.

For further rights concerning users residing in California, please refer to the "California Consumer Rights According to the CCPA" section.

0.7 Security and Storage of Your Information

We use the latest technology and protective safeguards to ensure that all data provided by users is secured against unauthorized access.

However, despite taking these strict measures, data breaches, hacking and cyberattacks are still potential risks when using internet-based services.

In the unlikely event of a security breach that compromises user data, we will actively work with the relevant authorities to investigate and respond to the situation.

In the case that personal data is compromised, all affected users will be notified and action will be taken in compliance with applicable laws.

We encourage users to maintain the security of their accounts by selecting strong passwords, to refrain from sharing personal data with other users via the Services and to use a secure device and operating system when using the Services.

This Privacy Policy is applicable to all data collected and stored by the Services.

Please note that we do not take responsibility in instances where third-party affiliates or their services (e.g., advertisements and links in/out of our website) collect your data.

Please ensure you have understood this Privacy Policy before using the Services.

0.8 EU-U.S. Privacy Shield

We fully comply with the U.S. Department of Commerce’s EU-U.S. Privacy Shield Framework through our utilization of Amazon Web Services (AWS).

All collected, processed and stored personal data transferred from the EU to the United States will adhere to the principles defined by the U.S. Department of Commerce and the European Commission as outlined in the Privacy Shield Framework.

For more information and details regarding AWS and its proof of certification, please refer to the following URL: https://aws.amazon.com/compliance/eu-us-privacy-shield-faq/
As outlined in this Privacy Policy, we will strive to ensure the security of all personal data collected by the Services and will take responsibility for any misuse of user data, except as otherwise provided.

Furthermore, in order to safely handle and store collected personal data (meaning data as defined in Article 16 Section 3 of the Japan Act on the Protection of Personal Information), we will take the necessary and appropriate measures to prevent the leakage, loss or damage of such data. If you would like further information regarding our data storage policies, please contact us using the contact information provided in the "Contact Address" section of this document.

Should a third party affiliated with us process user personal data in a manner that fails to comply with the principles outlined in the Privacy Shield Framework, we will take responsibility unless substantial proof is presented to refute our liability in the matter.

If you are an EU resident and have any questions or concerns about our policies regarding the Privacy Shield Framework, please contact us using the contact information provided in the "Contact Address" section of this document.

0.9 Age Limits and Restrictions

The minimum age to create an account in “Grand Summoners” is 13. If your country of residence recognizes a higher age of consent with regards to consensual data collection, parents or legal guardians must oversee and approve of the account creation process before any personal data is collected and stored by our services.

By agreeing to use our service, you acknowledge that you are considered an adult or of the age of majority in your country of residence. Minors below the legal age of majority are requested to not engage with our services, and to refrain from providing any personal data including, but not limited to: your name, mailing address, email address, and telephone number.

Under no circumstances will we collect or process the personal data of a minor without the consent of a parent or legal guardian. If it comes to light that any information collected by our service pertains to a minor, all stored data will be erased immediately.

If you have any suspicion that we might have collected data on a minor, please contact us via our email support system.

1.0 Information Disclosure

We have great respect for our users' privacy and rights.

All users have the option of requesting access to or disclosure of any of their information stored by the Services.

In order to submit such a request, please contact us using the contact information provided in the "Contact Address" section of this document.

In the event of such a request, we will be required to collect your name, date of birth, e-mail address, physical address, telephone number, and any additional information required in connection with the Service.

We will work swiftly to deliver the requested data following the confirmation of your personal data.

California Consumer Rights According to the CCPA

When collecting or using any information provided by users resident in California, where applicable, we promise to adhere to the clear general rules of the California Consumer Privacy Act of 2018 ("CCPA").

In regard to the Services, we are obligated to disclose information regarding our methods of collection and the disclosure of data to any third parties. Furthermore, as a resident of California, you have a legal right to exercise additional rights over any information we collect via our services.

Accordingly, this section primarily focuses on the rights granted by the CCPA to our users resident in California. For these users, in the event that information found in this section of the Privacy Policy contradicts a previous section, this section will take precedence.

As a resident of California, you have:

-The right to know: You may request that we disclose, free of charge, your personal data that we have collected, processed or shared within the 12-month period preceding your request.
-The right to delete: You may request that we delete your personal data collected in connection with your use of the Services. We will also instruct any service providers with whom we have shared your personal data to do the same.
-The right to non-discrimination: We do not discriminate against users based on their exercise of rights under the CCPA.
-The right to opt-out: You may request that we stop selling your personal data or that we do not sell your personal data in the future. That said, we do not sell our user's personal data.

We have great respect for our users’ privacy and rights. In order to request access to or disclosure of any data as outlined above, please contact us using the contact information provided in the "Contact Address" section of this document.

In the event of such a request, we will ask for your name, email address and any additional information required to process your request.

Should an authorized representative submit a request on behalf of a California resident, please provide the following additional documentation:

-Written and signed power of attorney from the user resident in California

-A form of identification to verify the authorized representative's identity

-Verification of the provided identity or designated power of attorney as outlined by the California Probate Code

The authorized representative’s identity is verified in accordance with the processes and procedures required or permitted by the CCPA and any other relevant laws. Accordingly, we may ask the representative for additional documentation needed to verify the person’s identity.

Contact Address

For inquiries regarding this Privacy Policy, please contact us using the information provided below.

Address: Sumitomo Fudosan Takanawa Park Tower 1F, 3-20-14 Higashigotanda, Shinagawa-ku, Tokyo 141-0022, Japan

Company Name: NextNinja Co., Ltd.

Email Address: grasum_global_support@nextninja.co.jp

CEO: Masayuki Yamagishi

We collect and use your personal data only for the following purposes.
The personal information we collect and use is the information provided to us voluntarily. If you provide us with your personal information, it means that you allow us to use that information so we can:
(1) to contact you, provide support, and to introduce products and services.