Coin & Decor Privacy Policy

Last Updated: May 1, 2025

This Privacy Policy ("Policy") explains how GIGBEING Inc. ("GIGBEING," "we," "us," or "our"), headquartered in Tokyo, Japan, collects, uses, shares, and otherwise processes your personal data when you use our smartphone game application "Coin & Decor" and any related services (collectively, the "Service"). "Personal data" means any information relating to an identified or identifiable natural person.

Please read this Policy carefully to understand our views and practices regarding your personal data and how we will treat it. By downloading, accessing, or using our Service, you acknowledge that you have read and understood this Policy. If you do not agree with this Policy, please do not use our Service.

Summary of Key Points

This summary provides a brief overview of our data practices. It does not replace the full Policy, which you should read for complete details.

• What personal data we collect: We collect information you provide (like your age or customer support inquiries), information automatically collected from your device and gameplay (like device identifiers, IP address, Advertising IDs, gameplay progress, interactions with ads, attribution data via Adjust), and information from third-party partners (like payment processors, advertising networks, and analytics providers). Crucially, your core game progress (Play Data) is stored only on your local device and will be lost if you uninstall the game or change devices.
• How we use your personal data: We use your data to provide and operate the Service, improve and personalize your experience, provide customer support, show advertisements (including rewarded ads and, with your consent where required by law, personalized ads), analyze game performance and ad campaign effectiveness (using tools like Adjust), ensure security, and comply with legal obligations.
• How we share your personal data: We may share your data with trusted third-party service providers who help us operate the Service (e.g., for hosting, analytics, advertising, attribution, customer support). This includes advertising partners like Unity Ads, Google AdMob, and ironSource (via Unity LevelPlay mediation), analytics providers like Unity Analytics, and attribution partners like Adjust. We may also share data if legally required, to protect our rights, or with your consent.
• Your rights and choices: Depending on your location, you have certain rights regarding your personal data, such as the right to access, correct, or delete your data, and to opt-out of certain data uses like targeted advertising and certain types of data processing by Adjust.
• Children's privacy: The Service is not directed to children under 13 (or a higher age if stipulated by local law for processing personal data, for example, 16 in some EEA countries for consent to processing). We implement age-gating and do not knowingly collect personal data from children below this age without verifiable parental consent. We do not show targeted advertising to users we know are under 16.
• International transfers: Your data may be processed in countries outside your own, including Japan and where our service providers (including Adjust) are located. We take steps to protect your data during these transfers.
• Data Retention: We keep your data for as long as necessary to provide the Service and for other legitimate business purposes.
• Contact us: If you have any questions or wish to exercise your rights, please contact us at info@gigbeing.com.

1. Scope of this Policy

This Policy applies to all users of our Service worldwide. It should be read in conjunction with our Terms of Service. This Policy does not cover the practices of third parties, including those whose services may be linked to or from our Service, or third-party advertisers. We are not responsible for the privacy practices of these third parties, and we encourage you to review their privacy policies.

2. Information We Collect

We collect information about you from various sources, as described below. The types of personal data we collect depend on how you use our Service and the requirements of applicable law.

(A) Information You Provide Directly to Us:

• Age Information: When you first use the Service, we will ask you to provide your age or date of birth. We use this information for age-gating purposes, to determine eligibility for certain features or content, and to tailor advertising experiences in compliance with applicable laws (e.g., not showing targeted or interest-based ads to users we know are under 16 years of age, or the relevant age in your jurisdiction for such consent).
• Customer Support Communications: If you contact us for customer support, to provide feedback, or for any other inquiry, we will collect your name (if you provide it), email address, and the content of your communications, including any information you choose to share about your issue or experience, and any attachments you send.
• Survey and Promotion Responses: If you choose to participate in surveys, contests, sweepstakes, or other promotional offers we may run, we will collect the information you provide in connection with those activities (e.g., contact details, survey answers, entry information).
• User-Generated Content (if applicable): If the Service allows you to create or share content (e.g., through in-game chat or forums, if such features are implemented), we will collect the content you create or share. Please be mindful of what you share, as it may be visible to other users.

(B) Information Collected Automatically When You Use the Service:

• Device Information:
  • Device type, manufacturer, and model.
  • Operating system name and version.
  • Unique device identifiers (e.g., Android ID, Identifier For Vendor (IDFV) for iOS, other platform-specific IDs).
  • Advertising Identifiers (IDFA for iOS, Google Advertising ID (GAID) for Android – collectively "Advertising IDs"). These identifiers may be resettable by you through your device settings.
  • IP address.
  • Language and region/country settings (derived from IP address or device settings).
  • Mobile network information and carrier (if applicable).
  • Time zone.
  • Browser type and version (if accessing web-based components of the Service, if any).
  • Screen resolution, CPU information, memory information, and other technical specifications of your device.
  • App version and build number.
• Usage Information (Gameplay Data & Analytics):
  • Details about how you use our Service, including your game progress, levels completed, scores, achievements, virtual items earned or purchased, In-game Currency balance and transaction history within the game.
  • Interactions with game features, tutorials, in-game events, offers, and other in-game elements.
  • Session start and end times, duration of play, and frequency of play.
  • Crash reports, error logs, and diagnostic data (e.g., battery level, loading times, latency, frame rates) to help us identify and fix technical issues and improve Service stability.
  • Referral source (e.g., how you found or were directed to our game, such as through an ad click or app store listing).
• Location Information:
  • We collect general location information (e.g., country, region, or city) derived from your IP address. This helps us comply with legal obligations, customize certain aspects of the Service (like language), provide region-specific content or features (if any), and for analytical purposes to understand where our players are located.
  • We do not collect precise GPS-based location data without your explicit prior consent.
• Advertising Interaction Information:
  • Information about the advertisements you are shown within the Service (e.g., which ads, how many times an ad is shown, your interactions with those ads such as views, clicks, or watching a rewarded ad to completion, and the ad network that provided the ad). This helps us and our advertising partners to show you relevant ads, measure their effectiveness, and manage ad frequency.
  • Information about your interactions with our own advertisements for the Service if you see them on third-party platforms (e.g., if you clicked on an ad that led you to install our game, and information about the advertising campaign).
• Attribution Information (via Adjust SDK and similar technologies):
  • To understand how users find and install our Service (e.g., which ad campaign or marketing channel led to the installation), we use attribution services like the Adjust SDK.
  • The Adjust SDK may collect information such as your Advertising ID, IP address, user agent, timestamps, device model, OS version, app version, carrier, language settings, install source (e.g., app store), and information about ad clicks or installs. This information helps us measure the effectiveness of our advertising campaigns, optimize our marketing spend, and detect fraudulent installs. Adjust may also use this data for its own service improvement and fraud prevention purposes. For more information on how Adjust processes data, please refer to Adjust's privacy policy (see Section 6).
• Cookies and Similar Tracking Technologies:
  • We and our third-party partners (such as analytics providers, advertising networks, and attribution partners like Adjust) may use cookies (small text files stored on your device), web beacons (also known as tracking pixels or clear GIFs), Software Development Kits (SDKs), and other similar tracking technologies. These technologies are used to collect information automatically about your device and how you use our Service. This helps us:
    • Operate and improve the Service, including remembering your preferences.
    • Understand usage patterns, analyze trends, and gather demographic information about our user base.
    • Deliver and measure the effectiveness of advertising, including personalized advertising where permitted by law and your consent.
    • Perform attribution and measure the effectiveness of marketing campaigns.
    • Prevent fraud and ensure the security of the Service.
  • For more details on our use of these technologies and your choices, please see Section 5 ("Advertising, Analytics, and Online Tracking").

(C) Information We Obtain from Third-Party Partners:

• Advertising Partners & Mediation Platforms: We work with third-party advertising networks and mediation platforms (such as Unity Ads, Google AdMob, and ironSource, which are managed through the Unity LevelPlay mediation platform) to display advertisements in our Service. These partners may provide us with information related to ad delivery and performance, such as your Advertising ID, details about ad impressions, clicks, and conversions (e.g., if an ad led to an install or an in-app action). These partners may also collect information directly from your device as described in their own privacy policies, which we encourage you to review. You can find more information about these partners and links to their privacy policies in Section 6.
• Attribution and Analytics Providers (e.g., Adjust, Unity Analytics): We use third-party services like Adjust for mobile measurement, attribution, and fraud prevention, and Unity Analytics for game analytics. These providers help us understand how users interact with our Service, measure the effectiveness of our advertising campaigns, and detect fraudulent activity. They may collect information such as your Advertising ID, device information, IP address, and usage patterns, and provide us with reports and insights. The information collected by these providers is subject to their respective privacy policies (see Section 6).
• Payment Processors: When you make in-app purchases (e.g., for In-game Currency or virtual items), the transaction is processed by the relevant app store provider (e.g., Apple App Store, Google Play Store) or their designated payment processors. We do not collect or store your full financial information, such as credit card numbers or bank account details. However, we receive transaction confirmations and details about your purchases (e.g., what was purchased, when, the cost, a transaction ID, and general location for tax purposes) from these processors to fulfill your order, maintain our records, and provide customer support.
• Social Media Platforms (If You Choose to Connect): If we offer, and you choose to log in to our Service or connect a social media account (e.g., Facebook, X, or other similar platforms) to our Service, we may receive certain information from that platform. This could include your public profile information (such as your name and profile picture), user ID associated with that platform, email address, and friend list (if you authorize the platform to share this with us). The information we receive depends on your privacy settings on that social media platform and the permissions you grant during the connection process. We will use this information in accordance with this Policy to, for example, allow you to share your game progress or connect with friends who also play the game.

Important Note on Play Data Storage:
As clearly stated in our Terms of Service, your core game progress, virtual items, In-game Currency, and other Play Data are stored locally on your Device only. We do not store this data on our servers. Consequently:

• If you uninstall the Service from your Device, your Play Data will be permanently lost.
• If you change to a new Device, your Play Data cannot be transferred.
• If your Device is lost, stolen, or damaged, your Play Data will be lost.
  We are not responsible for any loss of Play Data under these circumstances.

Special Categories of Personal Data:
We do not request or intend to collect any "special categories of personal data" (such as information revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership, genetic data, biometric data for the purpose of uniquely identifying a natural person, data concerning health, or data concerning a natural person's sex life or sexual orientation). Please do not provide this type of information to us or share it through the Service.

4. How We Use Your Information (Purposes and Legal Bases for Processing)

We use the information we collect for the purposes described below. If you are located in a jurisdiction that requires a legal basis for processing personal data (such as the European Economic Area (EEA), United Kingdom (UK), India, or other similar regions), we have also identified our primary legal bases for each purpose. The specific legal basis may vary depending on the context and the applicable local laws.

| Purpose of Use | Examples of Information Used | Legal Basis (Examples - may vary by jurisdiction and context)|
| To Provide and Operate the Service | Device Information, Usage Information (Gameplay Data & Analytics), Location Information, Account Information (if applicable), Payment Information | Performance of Contract (to provide core game features, process transactions, manage accounts, and deliver purchased items) |
| To Improve and Personalize the Service | Usage Information, Device Information, Advertising Interaction Information, Information from Third-Party Partners (Analytics Providers, Social Media Platforms) | Legitimate Interest (to understand player behavior, improve game balance, fix bugs, develop new features, personalize content and offers) and Consent (for personalization features requiring consent under applicable law) |
| To Provide Customer Support | Information You Provide Directly (Customer Support Communications), Account Information (if applicable), Device Information | Performance of Contract (to respond to inquiries and resolve issues) and Legitimate Interest (to improve our customer service) |
| To Show Advertisements (including Rewarded Ads) | Advertising Interaction Information, Device Information (Advertising IDs, IP Address, Location Information), Age Information | Legitimate Interest (to show non-personalized ads and rewarded ads) and Consent (for personalized/targeted advertising where required by law) |
| To Analyze Game Performance and User Engagement | Usage Information, Device Information, Advertising Interaction Information, Information from Third-Party Partners (Analytics Providers) | Legitimate Interest (to monitor service stability, identify trends, understand how users interact with the Service, and improve our offerings) |
| To Ensure Security and Prevent Fraud | IP Address, Device Information, Usage Information, Account Information (if applicable), Attribution Information (via Adjust) | Legitimate Interest (to protect our Service, users, and GIGBEING from fraudulent or illegal activities, and to enforce our Terms of Service) |
| To Comply with Legal Obligations | Information You Provide Directly, Device Information, Usage Information, Payment Information, Attribution Information | Legal Obligation (to comply with applicable laws, regulations, legal processes, or governmental requests) |
| For Marketing and Promotional Communications (Non-personalized) | Email address (if provided and consented for marketing), Usage Information (aggregated/anonymized) | Legitimate Interest (to inform users about updates, new features, and events related to the Service) or Consent (where required by law for direct marketing) |
| For Personalized Marketing and Promotions (where consent is obtained) | Advertising IDs, Usage Information, Device Information, Information from Third-Party Partners (Advertising Partners) | Consent (where required by applicable law for personalized marketing communications and offers) |
| To Manage User Accounts (if applicable) | Account Information, Information You Provide Directly | Performance of Contract (if account creation is part of the Service) and Legitimate Interest (for account management) |
| For Attribution and Ad Campaign Measurement | Advertising IDs, IP Address, Device Information, Ad Interaction Information, Attribution Information (via Adjust) | Legitimate Interest (to measure the effectiveness of our marketing campaigns, understand user acquisition channels, and optimize advertising spend) and Consent (where required by applicable law for certain tracking or profiling activities) |

5. Advertising, Analytics, and Online Tracking

We use advertising to help keep some aspects of our Service free. We also use analytics and attribution services to understand how our players use the Service and how effective our marketing efforts are, so we can improve both.

(A) Advertising:

• Types of Ads: We may show various types of ads in our Service, including contextual ads (based on the content of the game you are playing), banner ads, interstitial ads (full-screen ads shown between game levels or at natural breaks), and rewarded video ads (which you can choose to watch in exchange for in-game benefits).
• Personalized Advertising: Where permitted by applicable law and with your consent (where required), we and our advertising partners may use information collected about you (such as your Advertising ID, IP address, general location, and in-game activity) to show you ads that are more likely to be relevant to your interests. We do not show personalized ads to users we know are under 16 years of age (or a higher age if stipulated by local law for such consent).
• Advertising Partners: We use third-party advertising partners and mediation platforms, including Unity Ads, Google AdMob, and ironSource (managed through the Unity LevelPlay mediation platform), to serve ads in our Service. These partners may use their own SDKs, cookies, and other tracking technologies to collect information about your device and your interaction with ads. Their use of this information is governed by their own privacy policies. Please see Section 6 for more information on these partners.
• Opting Out of Personalized Advertising: You can generally opt-out of personalized advertising by adjusting your device's privacy settings.
  • For iOS devices: Go to Settings > Privacy & Security > Tracking, and turn off "Allow Apps to Request to Track" or manage permissions for individual apps. You can also go to Settings > Privacy & Security > Apple Advertising and turn off "Personalized Ads."
  • For Android devices: Go to Settings > Google > Ads, and tap "Delete advertising ID" or "Opt out of Ads Personalization."
  • Please note that opting out will not stop you from seeing ads, but the ads you see may be less relevant to you. The exact steps may vary depending on your device and operating system version.

(B) Analytics:

• We use analytics tools, such as Unity Analytics, to collect and analyze information about how you use our Service. This helps us understand player behavior, identify popular features, troubleshoot issues, and improve the overall game experience.
• The information collected by analytics tools may include your Advertising ID, device identifiers, IP address, device information, gameplay events, session duration, and other usage statistics.
• The data collected by Unity Analytics is subject to Unity's Privacy Policy (https://unity.com/legal/privacy-policy).

(C) Attribution Services (Adjust):

• We use Adjust, a mobile measurement and attribution platform, to understand how users find our Service (e.g., which advertising campaigns or channels led to an installation) and to measure the performance of our marketing activities.
• Adjust collects data through its SDK integrated into our Service. This data may include your Advertising ID, IP address, device type, operating system, app version, timestamps of activities (like install or in-app events), and information about the ad you clicked on that led to the install.
• This information helps us to attribute installs to specific marketing campaigns, understand the effectiveness of different advertising channels, optimize our advertising spend, and detect and prevent fraudulent advertising activities.
• Adjust acts as our processor for this data and may also use aggregated and anonymized data for its own service improvement and industry reporting. For more details on how Adjust processes data and your choices, please refer to Adjust's Privacy Policy (https://www.adjust.com/terms/privacy-policy/). You may also be able to opt-out of certain Adjust processing via their "Forget Device" feature or by contacting them directly as described in their policy.

(D) Cookies and Similar Technologies:

• As mentioned in Section 2(B), we and our partners (including advertising, analytics, and attribution partners like Adjust) use cookies and similar technologies. Cookies are small text files stored on your device that help us recognize your device and remember certain information about your preferences or past actions.
• Why we use them:
  • Essential Operations: Some cookies and SDKs are necessary for the Service to function properly (e.g., for security, fraud prevention).
  • Preferences: To remember your settings and preferences (e.g., language).
  • Analytics: To understand how you interact with our Service and improve it.
  • Advertising & Attribution: To deliver and measure ads, including personalized ads (with your consent where required), and to attribute app installs and other conversions to advertising campaigns.
• Your Choices: Most web browsers allow you to control cookies through their settings preferences. However, if you limit the ability of websites and applications to set cookies, you may worsen your overall user experience, as it may no longer be personalized to you. It may also stop you from saving customized settings like login information. For mobile devices, your device operating system provides settings to control how your Advertising ID is used for advertising purposes (see Section 5(A)). Some third-party SDKs, like Adjust, may offer their own opt-out mechanisms (see Section 5(C)).

6. Sharing and Disclosure of Your Information

We do not sell your personal data for monetary consideration. However, we may share your information with third parties in the following circumstances and for the purposes described in this Policy. We require third parties to respect the security of your personal data and to treat it in accordance with the law.

• Service Providers: We share your information with third-party companies and individuals who perform services on our behalf. These services include cloud hosting, data storage, analytics, advertising delivery and measurement, attribution, customer support, technical assistance, and payment processing (though we do not share full payment details with them, only transaction confirmations). These service providers are authorized to use your personal data only as necessary to provide these services to us and are contractually obligated to protect your data and process it in accordance with our instructions.
• Advertising Partners and Mediation Platforms: As described in Section 5, we share certain information (such as Advertising IDs, IP address, device information, general location data, and ad interaction data) with our advertising partners (e.g., Unity Ads, Google AdMob, ironSource) and the Unity LevelPlay mediation platform. This enables them to serve and optimize advertisements within our Service, including personalized ads (where you have consented, if required by law). These partners may act as independent controllers for the data they collect through their SDKs for their own purposes, as outlined in their respective privacy policies. We encourage you to review their privacy policies:
  • Unity (Ads, Analytics, LevelPlay, ironSource): https://unity.com/legal/privacy-policy
  • Google (AdMob & other Google services): https://policies.google.com/privacy
  • (Please note: This list is indicative and may be updated. We will endeavor to keep this information current.)
• Attribution and Fraud Prevention Partners (e.g., Adjust): We share information with partners like Adjust to measure the effectiveness of our advertising campaigns, attribute installations to specific sources, and to detect and prevent fraudulent activities. The information shared may include Advertising IDs, IP addresses, device information, and event data (e.g., installs, in-app events). Adjust's use of data is governed by its privacy policy:
  • Adjust: https://www.adjust.com/terms/privacy-policy/
• Analytics Providers: We share information with analytics providers like Unity Analytics to help us understand and improve the Service. This may include Advertising IDs, device information, IP addresses, and usage data.
• Legal Requirements and Protection of Rights: We may disclose your information if we believe in good faith that it is necessary to:
  • Comply with a legal obligation, court order, subpoena, or government request (e.g., from law enforcement agencies).
  • Enforce our Terms of Service or other agreements and policies.
  • Protect the rights, property, or safety of GIGBEING, our users, or others. This includes exchanging information with other companies and organizations for fraud protection, security, and credit risk reduction.
  • Detect, prevent, or otherwise address fraud, security, or technical issues.
• Business Transfers: In the event of a merger, acquisition, divestiture, reorganization, bankruptcy, dissolution, or other similar transaction or proceeding involving all or a portion of our business or assets, your personal data may be transferred as part of that transaction. We will notify you via email and/or a prominent notice on our Service of any change in ownership or uses of your personal data, as well as any choices you may have regarding your personal data.
• With Your Consent: We may share your information with other third parties when we have your explicit consent to do so for a specific purpose.
• Aggregated or De-identified Information: We may share aggregated or de-identified information, which cannot reasonably be used to identify you, with third parties for various purposes, including research, marketing, analytics, or to improve their services.

7. Your Data Protection Rights and Choices

Depending on your location and applicable data protection laws, you may have certain rights regarding your personal data. These rights are not absolute and may be subject to certain conditions or limitations under law. Your rights may include:

• Right to Access (Right to Know): The right to request access to the personal data we hold about you and to receive a copy of it, along with information about how we process it.
• Right to Rectification (Correction): The right to request that we correct any inaccurate or incomplete personal data we hold about you.
• Right to Erasure (Deletion or "Right to be Forgotten"): The right to request that we delete your personal data, under certain conditions. Please note that since Play Data is stored locally on your device, uninstalling the Service will delete this data from your device. For any data we may hold on our servers (e.g., customer support communications, or data collected by our analytics, advertising, or attribution partners linked to your Advertising ID, where we are the controller), you can request deletion. Deletion requests may be subject to legal retention obligations or other legitimate reasons for us to retain the data.
• Right to Restrict Processing: The right to request that we restrict the processing of your personal data, under certain conditions (e.g., if you contest the accuracy of the data, or if the processing is unlawful).
• Right to Data Portability: The right to receive your personal data, which you have provided to us, in a structured, commonly used, and machine-readable format and to have it transmitted to another controller without hindrance from us, under certain conditions.
• Right to Object to Processing: The right to object to our processing of your personal data, under certain conditions, particularly where we are processing your data based on our legitimate interests or for direct marketing purposes. If you object to processing for direct marketing purposes, we will cease processing your personal data for such purposes.
• Right to Withdraw Consent: If we are processing your personal data based on your consent (e.g., for personalized advertising in certain jurisdictions), you have the right to withdraw your consent at any time. Withdrawing consent will not affect the lawfulness of processing based on consent before its withdrawal.
• Right to Opt-Out of "Sale" or "Sharing" for Targeted Advertising (for residents of certain jurisdictions like California): While we do not "sell" personal data in the traditional sense for monetary payment, some data protection laws (like the California Consumer Privacy Act - CCPA/CPRA) define "sale" or "sharing" broadly to include the exchange of personal data for non-monetary benefits, such as when sharing Advertising IDs with ad networks for personalized advertising. You may have the right to opt-out of such "sales" or "sharing." You can typically exercise this by adjusting your device's advertising settings (see Section 5(A)) or through any in-app privacy controls we may provide.
• Rights Related to Automated Decision-Making and Profiling: You may have the right not to be subject to a decision based solely on automated processing, including profiling, which produces legal effects concerning you or similarly significantly affects you, except under certain conditions.
• Right to Lodge a Complaint: The right to lodge a complaint with a supervisory authority or data protection regulator in your jurisdiction if you believe that our processing of your personal data infringes applicable data protection laws.

How to Exercise Your Rights:
To exercise any of these rights, please contact us using the contact details provided in Section 13 ("Contact Us"). We will respond to your request in accordance with applicable data protection laws. We may need to verify your identity before processing your request. This may require you to provide information that matches the information we have on file, or in some cases, additional verification information. If you make a request through an authorized agent, we may require proof of their authorization.

Managing Your Information and Preferences:

• In-App Settings: Our Service may offer in-app settings that allow you to manage certain data preferences or opt-outs (e.g., for personalized advertising, if applicable and separate from device-level controls, or to manage consent for specific data processing activities).
• Device Settings: As mentioned in Section 5(A), you can control the use of your Advertising ID for personalized advertising and manage location service permissions through your mobile device's operating system settings.
• Adjust Opt-Out: Adjust provides users with the ability to opt-out of Adjust’s tracking for specific devices. You can typically find information on how to do this by visiting Adjust’s privacy policy or their "Forget Device" page (https://www.adjust.com/forget-device/).
• Uninstalling the Service: You can stop all further collection of information by GIGBEING through the Service by uninstalling the Service from all your devices. As noted, this will also delete your locally stored Play Data.

8. Children's Privacy

• Parental Rights: If you are a parent or guardian and believe that your child has provided us with personal data without your consent, please contact us at info@gigbeing.com. We will work with you to address the issue and, if appropriate, delete your child's information from our systems (to the extent it is held by us and not solely on the device).

9. International Data Transfers

GIGBEING is based in Japan. Your personal data may be collected, transferred to, stored, and processed in Japan and other countries where we or our third-party service providers (including advertising, analytics, and attribution partners like Adjust) have operations or servers. These countries may have data protection laws that are different from, and potentially less protective than, the laws of your country of residence.

When we transfer your personal data to other countries, we will take appropriate measures to ensure that your personal data receives an adequate level of protection in the jurisdictions in which it is processed, in accordance with applicable data protection laws. This may include relying on adequacy decisions adopted by relevant authorities (such as the European Commission's adequacy decision for Japan), implementing Standard Contractual Clauses (SCCs) or other approved transfer mechanisms with our third-party service providers, or obtaining your explicit consent for such transfers where required by law. By using our Service and providing us with your information, you understand that your information may be transferred to our facilities in Japan and to those third parties with whom we share it as described in this Policy, which may be located in countries outside of your country of residence.

10. Data Retention

We will retain your personal data for as long as necessary to fulfill the purposes for which it was collected, as outlined in this Policy, including for the purposes of satisfying any legal, accounting, or reporting requirements, to resolve disputes, or to enforce our agreements.

The criteria used to determine our retention periods include:

• The length of time we have an ongoing relationship with you and provide the Service to you (e.g., for as long as you have an account with us or keep using our Service).
• Whether there is a legal obligation to which we are subject (for example, certain laws require us to keep records of your transactions or communications for a certain period of time before we can delete them).
• Whether retention is advisable in light of our legal position (such as in regard to applicable statutes of limitations, litigation, or regulatory investigations).
• The nature and sensitivity of the personal data.

Since Play Data is stored locally on your device, its retention is primarily controlled by you (e.g., by uninstalling the game). Information collected by our third-party partners (e.g., analytics, advertising, and attribution partners) is subject to their own retention policies, which we encourage you to review. When we no longer need your personal data for the purposes set out in this Policy, we will take steps to delete it or anonymize it, unless we are required by law to keep it for a longer period.

11. Data Security

We have implemented and maintain reasonable administrative, technical, and physical security measures designed to protect your personal data from unauthorized access, use, loss, alteration, and disclosure. These measures include, for example, data encryption where appropriate, access controls to our systems, and staff training on data protection.

However, please be aware that no security measures are perfect or impenetrable. Despite our efforts, we cannot guarantee the absolute security of your personal data. Any transmission of data is at your own risk. We encourage you to take precautions to protect your personal information when you are on the Internet, such as using strong passwords, keeping your software up to date, and being cautious about the information you share online. If you have reason to believe that your interaction with us is no longer secure (for example, if you feel that the security of any account you might have with us has been compromised), please immediately notify us of the problem by contacting us in accordance with the "Contact Us" section below.

12. Changes to This Privacy Policy

We may update this Policy from time to time to reflect changes in our practices, technologies, legal requirements, or other factors. When we make changes, we will revise the "Last Updated" date at the top of this Policy. If we make material changes to this Policy (i.e., changes that significantly affect your rights or the way we handle your personal data), we will provide you with more prominent notice as required by applicable law. This may include posting a notice within the Service, on our website, or by sending an email to you if we have your email address and are permitted to contact you.

We encourage you to review this Policy periodically to stay informed about our information practices and the ways you can help protect your privacy. Your continued use of the Service after any changes to this Policy are posted will be deemed acceptance of those changes, unless applicable law requires a different form of acknowledgement or consent.

13. Contact Us

If you have any questions, comments, or concerns about this Policy or our privacy practices, or if you wish to exercise your data protection rights, please contact our Privacy Officer at:

GIGBEING Inc.
Attn: Privacy Officer
2-30-4 Yoyogi, Shibuya-ku,
Tokyo, 151-0053
Japan
Email: info@gigbeing.com

Please include your name, contact information, and the nature of your request or concern so that we can respond appropriately and efficiently. We will endeavor to respond to your inquiry within a reasonable timeframe and in accordance with applicable law.

14. Region-Specific Information

This section provides additional information relevant to users in certain jurisdictions.

For users in the European Economic Area (EEA), United Kingdom (UK), and Switzerland:

• Data Controller: For the purposes of the General Data Protection Regulation (GDPR) and other relevant data protection laws in these regions, GIGBEING Inc. is the data controller for your personal data.
• Legal Bases for Processing: As outlined in the table in Section 4, our legal bases for collecting and using your personal data include:
  • Performance of a contract: When processing is necessary to provide you with the Service as described in our Terms of Service or to fulfill your requests (e.g., processing in-app purchases).
  • Legitimate interests: When processing is necessary for our legitimate interests (or those of a third party), provided that your interests and fundamental rights do not override those interests. Examples include improving the Service, conducting analytics, preventing fraud, ensuring security, and providing non-personalized advertising. We conduct a balancing test for processing based on legitimate interests.
  • Consent: When we rely on your consent for specific processing activities, such as for personalized advertising (where required by law), use of non-essential cookies or similar technologies, or collection of precise location data. You have the right to withdraw your consent at any time.
  • Compliance with a legal obligation: When processing is necessary for us to comply with our legal obligations.
• Your Rights: You have the rights described in Section 7, including the right to access, rectify, erase, restrict processing of, and port your personal data, as well as the right to object to processing (particularly processing based on legitimate interests or for direct marketing) and withdraw consent. You also have the right to lodge a complaint with a supervisory authority in your country of residence, place of work, or where an alleged infringement of data protection law occurred.
• International Transfers: When we transfer your personal data outside the EEA, UK, or Switzerland to countries not deemed to provide an adequate level of data protection by the relevant authorities (such as Japan, which has an adequacy decision from the European Commission, or the United States), we rely on appropriate safeguards. These may include Standard Contractual Clauses (SCCs) approved by the European Commission or the UK Information Commissioner's Office, or other lawful transfer mechanisms. You can request more information about these safeguards by contacting us.

For users in California, USA:

This section provides additional details required by the California Consumer Privacy Act (CCPA) as amended by the California Privacy Rights Act (CPRA). For purposes of this section, "Personal Information" has the meaning given in the CCPA/CPRA.

• Categories of Personal Information Collected: In the preceding 12 months, we have collected the categories of Personal Information described in Section 2 of this Policy. This may include:
  • Identifiers (e.g., Advertising IDs, IP addresses, device identifiers, email address if you contact support).
  • Internet or other electronic network activity information (e.g., gameplay data, interactions with ads, usage of Service features).
  • Geolocation data (general location derived from IP address).
  • Commercial information (e.g., records of in-app purchases).
  • Inferences drawn from any of the above to create a profile about your preferences and characteristics.
• Sources of Personal Information: We collect this information from you directly, automatically from your device and your use of the Service, and from our third-party partners as described in Section 2.
• Purposes for Collecting, Using, and Disclosing Personal Information: We collect, use, and disclose Personal Information for the business and commercial purposes described in Section 4 and Section 6 of this Policy.
• Categories of Personal Information Disclosed for a Business Purpose: In the preceding 12 months, we may have disclosed the categories of Personal Information listed above to service providers and third-party partners for business purposes as described in Section 6. This includes disclosures to our analytics providers, advertising technology partners (for serving contextual and, with consent where required, personalized ads), customer support providers, and payment processors.
• "Sale" or "Sharing" of Personal Information: California law defines "sale" and "sharing" broadly. While we do not sell your Personal Information for monetary consideration, our use of third-party advertising and analytics services (like those described in Sections 5 and 6) may involve the "sharing" (as defined under CCPA/CPRA) of your Personal Information (such as Advertising IDs, IP addresses, and online activity information) with these partners for cross-context behavioral advertising (which is a form of targeted advertising).
• Your California Privacy Rights:
  • Right to Know/Access: You have the right to request information about:
    • The categories of Personal Information we have collected about you.
    • The categories of sources from which the Personal Information is collected.
    • The business or commercial purpose for collecting, selling, or sharing Personal Information.
    • The categories of third parties to whom we disclose Personal Information.
    • The specific pieces of Personal Information we have collected about you.
  • Right to Delete: You have the right to request the deletion of your Personal Information that we have collected from you, subject to certain exceptions (e.g., where the information is necessary to provide the Service, complete a transaction, detect security incidents, or comply with a legal obligation).
  • Right to Correct: You have the right to request the correction of inaccurate Personal Information that we maintain about you.
  • Right to Opt-Out of Sale/Sharing: You have the right to opt-out of the "sale" or "sharing" of your Personal Information for cross-context behavioral advertising. You can typically exercise this right by adjusting your device's advertising settings as described in Section 7 ("Advertising ID Opt-Out") or through an in-app privacy settings menu if available. Our Service will also process Global Privacy Control (GPC) signals as an opt-out of sale/sharing where technically feasible.
  • Right to Limit Use and Disclosure of Sensitive Personal Information: We do not collect or process "sensitive personal information" as defined by the CCPA/CPRA for the purpose of inferring characteristics about you.
  • Right to Non-Discrimination: We will not discriminate against you for exercising any of your CCPA/CPRA rights. This means we will not deny you goods or services, charge you different prices or rates, or provide you a different level or quality of goods or services.
  • To exercise these rights, please contact us as described in Section 13 ("Contact Us"). We will verify your request using the information associated with your use of the Service or by asking you to provide information that matches information we have on file. You may also designate an authorized agent to make a request on your behalf. The authorized agent must provide proof of their authorization, and we may also require you to verify your own identity directly with us.
  • We do not have actual knowledge that we "sell" or "share" the personal information of consumers under 16 years of age.

For users in India:

• Consent: We will obtain your consent for the collection and processing of your personal data where required by the Digital Personal Data Protection Act, 2023 (DPDP Act) or other applicable Indian laws.
• Children's Data: If you are under the age of 18, we will process your personal data only with the verifiable consent of your parent or legal guardian, as required by the DPDP Act. We will not undertake tracking or behavioral monitoring of children or targeted advertising directed at children that can cause harm.
• Your Rights: You have certain rights under the DPDP Act, including the right to access information about processing, the right to correction and erasure of your personal data, the right to grievance redressal, and the right to nominate another person to exercise your rights in case of your death or incapacity.
• Data Protection Officer: Our contact details for privacy-related queries are provided in Section 13. If you have a grievance, you may contact our designated Grievance Officer through the same contact details.
• International Transfers: Your personal data may be transferred outside of India as described in Section 9. We will ensure such transfers comply with the requirements of the DPDP Act.

For users in other jurisdictions:
We are committed to complying with applicable privacy laws in all jurisdictions where we offer our Service. If you have specific questions or concerns related to your local privacy laws, or wish to exercise rights available to you under such laws, please contact us using the details in Section 13 ("Contact Us").

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