Complex Games Inc. Privacy Policy

Terms of Use

Privacy Policy

This privacy policy (hereinafter “Policy”) is intended to provide for the handling of your (“User’s” or “User”) personal information and activity information such as access history (hereinafter “History Information”; collectively with personal information referred to as “Personal Information, etc.”) when using the website and the application (hereinafter this “Service”) operated by Complex Games,Inc. (hereinafter the “Company”). This Policy constitutes part of the “Terms and Conditions”. This Policy is applicable when a User uses this Site and when the Company manages personal information, etc. acquired from the User.

However, this Policy does not apply to personal information, etc. acquired from each User by advertisers running advertisements on this Site or persons who provide information and services through this Site, etc. It also does not apply to persons other than the User of this Site.

1. Definitions and Protection of Personal Information

  1. For the purpose of this Policy, “Personal Information” shall mean information such as the name, device identifiers, ip addresses, social networking tokens, and e-mail address of the User (however, limited to an individual) which can identify a specific individual by such description (including information that can be easily compared with other information and thereby identify the specific individual).

  2. The Company is the sole owner of the personal information of the User (hereinafter “User’s Personal Information”) acquired on this Site of the Company, and the Company shall manage the User’s Personal Information in accordance with this Policy.

2. Acquisition and Storage of Personal Information

At the time the User registers for membership, the Company may request the User to provide personal information such as an e-mail address, prefecture of residence, gender, date of birth, occupation, etc. Also, if it becomes necessary to provide other services, to the extent necessary, the User may be asked to provide his/her personal information.

The Service collects the following information from the User upon login: an advertising identifier, tokenized social networking identifiers, GeoIP, IP address, device make, model, and operating system.  Android and Amazon users provide a hashed device identifier. Personal Information is kept for the duration of the life of the Service.

Users may choose to provide e-mail, twitter, or facebook contact information for the purpose of sending support Help Requests and receiving replies.

3. Purpose of Use of Personal Information.

The purposes of use of personal information by the Company are as follows. As a general rule, the Company shall not use the personal information of Users for any other purpose, unless it is not necessary to notify the person of the purpose in advance or publicly announce the purpose as required by the “Act on the Protection of Personal Information” (hereinafter “Personal Information Protection Act”)

(a)  Providing the Services and Support of this Site and the Apps created by the Company

(b) Handling disputes and litigation, etc.

(c) Providing notices about information such as new services, etc.

(d) Market research, analysis, etc.

(e) Sending prizes to those who are winners in prize programs, etc.

(f) Providing ads from the Company or information from advertisers

4. Provision to Third Parties.

The Company will not provide personal information of the User to a third party without the consent of the User. However, in the following cases, and to the extent permitted by the Personal Information Protection Act, the Company may provide or disclose the User’s Personal Information to third parties.

(a) If the User consents to his/her personal information being provided or disclosed to a third party

(b) If it is necessary to provide the User’s personal information to a subsidiary of the Company or a party entrusted with personal information set forth in Paragraph 5 in order to achieve the purpose of use set forth in Paragraph 3

(c) If the Company is subject to a judgment, order, referral, or request from a court, police, tax authorities, consumer advocate center, or any other institution with the authority as recognized by laws and regulations

(d) If it is deemed necessary by the Company in order to protect a third party’s or the Company’s life, body, rights, or assets, and the Company determines that it will be difficult or inappropriate to obtain the consent of the User

The Company uses the following third parties to help provide the Service of this Site and the Apps created by the Company.  Those parties and their privacy policies are listed below:

Ironsource                             Facebook

Twitter                                  iOS App Store

Google Play Store                  Amazon App Store

Amazon Web Services           Applovin

Unity Ads/Unity Analytics      Ad Colony

AppsFlyer                            Newrelic

5. Entrusting of Personal Information

When the Company outsources the User support services or the system improvement, maintenance, and data processing services to a third party, the Company may entrust your personal information to that third party. In doing so, the Company selects third party contractors on the condition that they ensure a high level of personal information protection, and have them sign a confidentiality agreement before entrusting the personal information.

6. Disclaimer

If the User voluntarily discloses his/her personal information, etc. on the Site (including, but not limited to, e-mail and bulletin boards) without a request from the Company, such information may be collected and used by a third party. Even in the event that the User incurs any damage therefrom, the Company shall not be held liable whatsoever.

7. Disclosure, Correction or Deletion, etc., of the User’s Personal Information

If the User makes a request to disclose, correct, add, delete, or suspend the use of his/her personal information, the Company shall implement, to a reasonable extent and as soon as possible, the measures to disclose, correct, add, delete, or suspend the use of such personal information, after identifying the User through a process deemed appropriate by the Company.

Should a User wish to acquire a copy of their Personal Information or have their Personal Information removed or changed they should contact The Company’s support services at: dropassault@complexgames.com

8. Acquisition of History Information

This Service has pages that require cookies for acquiring History Information. A cookie is a small text file used by the server to send data to the User’s personal computer when a User visits this Service, and it is not possible to identify a User just by the information stored in the cookie. This Service uses cookies to manage log-ins and collect statistical information. In addition, this Service may use cookies or web beacons, etc. for companies or third party businesses that display ads for advertisement distribution, measurement of the effects, improvement of conveniences, etc. The use of cookies or web beacons in this case shall be in accordance with each company’s concept of privacy. Users can refuse cookies by changing the settings of the browser they are using. Please understand that it may not be possible to use part of this Service when refusing cookies.

9. Revision of this Policy

The Company may revise all or part of this Policy without the consent of the User. However, if the Company determines it is a significant change, the User will be notified on this Site in a way easy to understand.

10. Others

For Children under age 13 (This paragraph applies to User in the United States only.)

The Children’s Online Privacy Protection Act (Federal Trade Commission, United States of America) imposes certain rules regarding the collection, use and disclosure of personal information from children under the age of 13. We ask that parents and guardians monitor and restrict their children’s access to and use of the Service. We do not knowingly collect or solicit personal information from anyone under the age of 13 or knowingly allow such persons to use the Service. If you are under 13, please do not attempt to use the Service or send any information about yourself to us, including your name, address, telephone number, or email address. No one under the age of 13 may provide any personal information. In the event that we learn that we have collected personal information from a child under age 13, we will delete that information as quickly as possible.

Supplemental Provisions

Enacted November 7, 2014 [CZPP07+LCW01088]

Updated May 24, 2018