Privacy Policy

Original Effective Date: June 27th, 2022
Last Updated: July 26th, 2024

Cygames, Inc., as well as its subsidiaries and affiliated entities, (“Cygames,” “we,” or “us”) takes the protection of your personal data very seriously. The following Privacy Policy will provide you with information about personal data that we collect and how it is processed and used.

PLEASE READ THIS PRIVACY POLICY CAREFULLY BECAUSE BY USING THE SERVICES, YOU CONSENT TO THE TERMS AND CONDITIONS OF THIS PRIVACY POLICY AND TO OUR PROCESSING OF PERSONAL DATA FOR THE PURPOSES STATED BELOW. IF YOU DO NOT AGREE WITH THE TERMS AND CONDITIONS OF THIS PRIVACY POLICY, PLEASE DO NOT USE THE SERVICES.

In order to ensure the secure processing of your personal data, we have implemented all safeguards required by law.

1. Scope of This Privacy Policy

This Privacy Policy applies only to services related to “Little Noah: Scion of Paradise” controlled by Cygames (the “Services”).

2. Personal Data Collected (Categories and Sources of Personal Data)

We may collect the following personal data:

  • Your name and email address, if you provide them to us
  • Whether you are currently using the Services or you are still considering using the Services, and if you are currently using the Services, the version of the Services you are using
  • Your Internet Protocol (IP) address, cookies, and other online identifiers
  • Your behavioral data on the internet including browsing history and information on your interaction with a website
  • Your date of birth and/or telephone number if necessary for us to provide the Services
  • Device information
  • Countries/areas where you live
  • Log information
  • Account name relating to a game platform
  • Contents of your inquiries, including problems you experience, if you contact us to make inquiries
  • Inferences drawn from personal data to create your profile reflecting a person’s preferences or behavior and the like
  • Other personal data required to provide the Services (Category of data is separately notified to you if required to do so under applicable data protection regulations.)

Personal data is collected directly from you, collected indirectly from third parties such as service providers, or inferred from collected data.

For residents of California, please take note of the following additional information.

We have collected the following categories of personal information under the California Consumer Privacy Act or “CCPA” (Cal. Civ. Code § 1798.100 et seq.) from and about you in the preceding 12 months:

  1. Identifiers including names, unique personal identifiers, cookies, online identifiers, Internet Protocol addresses, email addresses, account names, or other similar identifiers
  2. Personal data contained in customer records including names
  3. Commercial information including records of services purchased, obtained, or considered; or other purchase or consumption histories or tendencies
  4. Internet or other similar network activities including browsing history and information on your interaction with a website
  5. Geolocation data
  6. Inferences drawn from personal data to create your profile reflecting a person’s preferences or behavior and the like

3. Cookies

We use cookies in the Services.

Cookies are small text files that websites send to your device for the purpose of keeping records. Cookies identify your device, and typically your web browser. Some cookies are necessary to operate our website (e.g., establishing sessions), while other cookies provide enhanced functionality, gather analytical data to improve performance, enable us or our AdTech partners to deliver personalized advertisements by tracking you across the Internet, or enable sharing via social media.

You can choose whether to allow us or third parties (e.g., our analytics, AdTech and social media partners) to set cookies which are not strictly necessary for the functioning of our website via the cookie banner and settings provided on our website.

Please be aware that when we talk about “cookies”, this term also includes other technologies (such as pixel tags and web beacons) which have the same purpose as cookies described in this Privacy Policy.

First-party cookies are put on your device directly by the website you are visiting.

Third-party cookies are placed on your device, not by the website you are visiting, but by a third party such as an advertiser or a provider of analytics software.

Permanent cookies remain on your device when the website is closed and will be used on subsequent visits to our website.

Session cookies are temporary and expire once you close your browser (or once your session ends).

If you would like to know the details of our use of cookies and change settings for the use of cookies, please refer to our Cookie Settings.

You may also set most browsers to notify you if you receive a cookie, or you may choose to block cookies with your browser. If you do so, you may not be able to take advantage of the personalized features enjoyed by other users of the Services.

For residents of the European Economic Area and the UK, the following shall also apply:

We will process cookies (except for strictly necessary cookies) as well as your personal data obtained through cookies for the purposes outlined in Article 5 based on your consent. You may withdraw your consent to this processing at any time by using our Cookie Settings. However, this will not affect the lawfulness of any processing carried out before you withdrew your consent. We will process strictly necessary cookies as well as your personal data obtained through cookies for the purposes outlined in Article 5 (Use of Personal Data) based on legitimate interests.

4. Use of Tracking Tools or the Like Provided by Third Parties

We use Google Analytics. Google Analytics is a web analytics service provided by Google LLC (“Google”) which collects anonymous statistical and analytical information about how our users use the Services. For example, Google gathers and aggregates data on page views and clicks on the Services. These analytics are not used to track your journey to other websites or to identify you. The information generated by the Google Analytics cookies about your use of the Services (including your IP address) will be transmitted to and stored by Google on servers in the United States.

You can find a more detailed account of Google’s privacy policy here:

https://policies.google.com/privacy?hl=en.

5. Use of Personal data

We may process your personal data for the purposes described below:

  • To deliver content such as games, video, and music; and provide related services
  • To develop services; compile statistics, analysis, and questionnaires; and conduct other marketing activities intended to improve services
  • To contact and communicate with you to respond to your inquiries and complaints
  • To provide you with special offers, campaign information, updated information and other new services, newsletters, and any other information from Cygames or other third parties
  • To complete a transaction or service requested by you
  • To fulfill marketing or promotional purposes
  • To allow you to share the link to our contents on social networking services
  • To improve the Services
  • To create and publish content that is the most relevant to you
  • To notify you about a change to this Privacy Policy or the Terms of Service Agreement, if necessary
  • To resolve disputes with you
  • For other purposes of use as separately disclosed

Provision of your personal data is mandatory in some cases for a statutory reason, contractual requirement, or a requirement necessary to enter into a contract, etc. We may be unable to provide our service to you if you don’t provide such personal data.

For residents of the European Economic Area and the UK, the following shall also apply:

We will always process your personal data based on one of the legal bases provided for in the GDPR (Articles 6 and 7). We process your personal data for the purposes stipulated in the following paragraphs based on the legal grounds listed below.

(a) Performance of a contract (Article 6(1)(b) of the GDPR)

We process your personal data for the following purposes because it is necessary for the performance of a contract or in order to take steps at the request of the data subject (that is, you) prior to entering into a contract.

  • To deliver content such as games, video, and music; and provide related services
  • To contact and communicate with you to respond to your inquiries and complaints
  • To complete a transaction or service requested by you
  • To notify you about a change to this Privacy Policy or the Terms of Service, if necessary
  • To resolve disputes with you

(b) Legitimate interests (Article 6(1)(f) of the GDPR)

We process your personal data for the following purposes because it is necessary to do so in order to pursue our legitimate interests (Article 6(1)(f) of the GDPR).

  • To develop services; compile statistics, analysis, and questionnaires; and conduct other marketing activities intended to improve services
  • To fulfill marketing or promotional purposes
  • To improve the Services
  • To create and publish content that is the most relevant to you
  • To allow you to share the link to our contents on social networking services
  • To process strictly necessary cookies

(c) Consent (Article 6(1)(a) of the GDPR)

We process your personal data for the following purposes based on your consent (Article 6(1)(a) of the GDPR).

  • To process cookies (except for strictly necessary cookies) as well as your personal data obtained through such cookies
  • To provide you with special offers, updated information and other new services, newsletters and any other information from Cygames or other third parties

6. Disclosure to Third Parties

We may share or disclose your personal data specified in Article 2 (Personal Data Collected (Categories and Sources of Personal Data)) to the extent necessary with or to third parties for the following purposes.

  • To provide the Services to you, we may disclose your personal data to service providers. Service providers include agents or independent contractors, such as Zendesk Inc., Explay, Inc., GREE Inc, and Keywords International Co., Ltd., which provide customer service, help us maintain the Services, and provide other administrative services to us. In addition, to store and manage data on servers, we may use Amazon Web Services, Inc. and other cloud services providers to process your personal data. We may also disclose your personal data to service providers who provide services to evaluate the effects of advertisement. When engaging service providers, we enter into agreements for the protection of personal data with the delegated parties and request consent to the terms and agreements thereof so as to safely manage personal data.
  • Collection by social networking service providers and video distribution platforms: Buttons through which you can share our content on social media or video links to video distribution platforms may be embedded in our websites. In this case, the social networking service providers and video distribution platforms may obtain your personal data.
  • To comply with laws and regulations, we may share personal data when necessary or in the good faith belief that such action is necessary under the requirements of a law or regulation, a legally-binding court order, or a governmental order from an investigative agency or competent regulatory authority that is issued with due process, to protect and defend our rights or property or both, or to act in urgent circumstances when it is necessary to protect the life, body, or property of a person, and the consent of the identified individual is difficult to obtain.
  • We may share or disclose personal data with or to third parties as part of any corporate reorganization process including, but not limited to, mergers, acquisitions, and sales of all or substantially all of our assets.

For residents of California, please take note of the following additional information.

We have disclosed the following categories of personal information under the CCPA for business purposes to the following categories of recipients in the preceding 12 months.

Category of Personal information Categories of Recipients
Identifiers Service providers including cloud service providers, social networking service providers, and video distribution platforms
Personal data categories contained in customer records Service providers including cloud service providers
Commercial information Service providers including cloud service providers
Internet or other similar network activity Service providers including cloud service providers, social networking service providers, and video distribution platforms
Geolocation data Service providers including cloud service providers
Inferences drawn from personal data Service providers including cloud service providers

7. Security

No data transmissions over the Internet can be guaranteed to be 100% secure. Consequently, we cannot ensure or warrant the security of any information that you transmit to us, and you understand that any information that you transfer to Cygames is transmitted at your own risk. Cygames specifies rules for the protection of personal data, and incorporates appropriate administrative, technical, organizational, and physical security measures that are required under applicable regulations. We use firewalls to protect your information from unauthorized access, disclosure, alteration, or destruction. However, please note that this is not a guarantee that such information may not be accessed, disclosed, altered or destroyed by breach of said firewalls and secure server software.

If we learn of any security systems breach, we may attempt to notify you electronically so that you can take the appropriate protective measures. By using the Services or providing personal data to us, you agree that we can communicate with you electronically regarding security, privacy, and administrative issues relating to your use of the Services. We may post a notice on our Services if a security breach occurs. We may also send an email to you at the email address you have provided to us.

8. Rights of Data Subjects

We respect the rights you have under the personal data protection regulations applicable to you. You may demand the disclosure of, correction of, addition to, or deletion in the content of; stoppage or elimination of usage of; or stoppage of third-party provision of your personal data or disclosure of records for the provision of your personal data to third parties pursuant to the Act on the Protection of Personal Information of Japan. In addition to these rights, other rights may be granted to you under the applicable personal data protection regulations of other countries, as may be applicable. For example, in accordance with personal data protection regulations of an applicable country, you may be granted the following rights, and if the conditions prescribed by such personal data protection regulations are satisfied, we will comply with your exercise of such rights.

  • Access to your personal data:
    The right to obtain confirmation from us on whether your personal data has been or is being processed, and if it has been or is being processed, the right to access the relevant personal data and specific related information.
  • Correction of your personal data:
    The right to modify incorrect personal data regarding you without unreasonable delay and the right to complete your personal data that is incomplete.
  • Deletion of your personal data:
    The right to delete personal data related to you without unreasonable delay.
  • Restriction on the processing of your personal data:
    The right to restrict the processing of your personal data.
  • Objecting to the processing of your personal data:
    The right to file an objection to the processing of your personal data which affects your rights.
  • Withdrawal of consent:
    The right to withdraw your consent on which we rely to process your personal data.
  • Data portability:
    The right to receive your personal data in a structured and generally machine-readable form, and the right to transfer the data to third parties without interference from us.

If you wish to exercise any of the foregoing rights, please inquire with us using the contact information stated in Article 15 (Contacting Us). In order to confirm your identity, it may be necessary for us to ask for specific information from you. In addition, in order to streamline correspondences from us, we may contact you to ask for additional information in connection with your inquiry.

Further, you may directly file a complaint with the relevant supervisory agency in connection with our processing of your personal data.

For residents of the European Economic Area and the UK, the following shall apply:

If certain conditions are satisfied, you will have the right of access to your personal data, correction of your personal data, deletion of your personal data, restriction on the processing of your personal data, filing an objection to the processing of your personal data, withdrawal of consent, and data portability.

For residents of California, the following shall apply:

California Civil Code, Section 1798.83, permits California residents to request certain information regarding disclosure of personal information under the CCPA to third parties for their direct marketing purposes. We do not share personal information for third parties’ direct marketing purposes.

You have the right to know and the right to access information about the categories and specific pieces of personal information we have collected about you, as well as the categories of sources from which such information is collected, the purpose for collecting such information, and the categories of third parties with whom we share such information. You also have the right to know if we have sold or disclosed your personal information. You may request a copy of your personal information which we have collected, and upon request, we will provide this information to you in electronic form.

You have the right to request information about our sale or disclosure for business purposes of your personal information to third parties.

You have the right to opt out of the sale of your personal information to third parties. Please note, we do not sell your personal information at this time.

You also have the right to request the deletion of your personal information, subject to certain legal exceptions.

California residents have the right not to be discriminated against for exercising the foregoing rights. If you would like to exercise these California rights, please contact us using the contact information provided in Article 15 (Contacting Us). You may also designate an authorized agent registered with the California Secretary of State to make a request on your behalf. The authorized agent must have written permission to submit requests on your behalf. Whenever feasible for verification, we will match the identifying information provided by you with the personal information already maintained by us. If, however, we cannot verify your identity from the information already maintained by us, we may request additional information.

For residents of South Korea, the following shall apply:

If we use consent as the legal ground to process personal data, then after you withdraw your consent to the processing, we will stop processing your personal data unless there is another legal basis for such processing (e.g., statutory retention periods).

9. Retention Period

We retain personal data for as long as necessary to fulfill the purposes for which we collected it, including for the purposes of satisfying any legal, accounting, or reporting requirements, to establish or defend legal claims, or for compliance and protection purposes.

To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorized use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.

10. International Transfer of Information

Personal data which you choose to provide to us will be stored in Japan. We may transfer (by any means including sending or allowing access) that information to countries or areas outside of the country or area where you live in accordance with applicable laws and regulations. At this moment, we transfer personal data to Japan and the United States. In addition, our service providers also use cloud servers provided by AWS, and your personal data may be processed in any of the regions or edge locations stated in the page below:

https://aws.amazon.com/about-aws/global-infrastructure/regions_az/

Such personal data may be processed by such parties for the term necessary to fulfill purposes specified in Article 6 (Disclosure to Third Parties).

For residents of the European Economic Area and the UK, the following shall also apply:

If an adequacy decision is made with respect to a third country, we share or disclose your personal data to a person in that third country on the basis of the adequacy decision (Article 45 of the GDPR). If no adequacy decision is made with respect to a third country, we share or disclose your personal data to a person in that third country by executing with the transferee the standard data protection clauses (https://ec.europa.eu/info/law/law-topic/data-protection/international-dimension-data-protection/standard-contractual-clauses-scc_en) (Article 46(2)(c) and (5) of the GDPR) approved by the European Commission.

11. Third Party Services

This statement applies solely to information collected on the Services. The Services may contain links to other webservices. We are not responsible for the privacy practices or the contents of these other web services.

12. Changes to this Privacy Policy

We reserve the right to change this Privacy Policy from time to time. When we do, we will also revise the “last updated” date at the top of this Privacy Policy. For some changes to this Privacy Policy we may attempt to obtain your consent before implementing the change by placing a notice on the Services. The continued use of the Services following such notice will be viewed as consent to such changes unless otherwise specified.

13. Online Tracking

Certain web browsers and other programs may be used to signal your preferences to us about how or whether we or third parties may collect information about your online activities. Because there is not yet an accepted standard for how to respond to a “Do Not Track” (DNT) signal, we do not support DNT browser settings and do not currently participate in any DNT frameworks that would allow us to respond to signals or other mechanisms from you regarding the collection of your personal data or non-personal data.

14. Our Policy Regarding Children

We do not knowingly collect or solicit personal information from anyone under the age of 13. If you are under 13, please do not send any personal information, and please ask help from your parents and other legal guardians. If we learn that we have collected personal information from a child under the age of 13 without legal grounds, we will delete the information as quickly as possible. If you believe that we may have any information from or about a child under the age of 13 without legal grounds, please contact us using the online form (https://littlenoah-s.com/en/contact/).

15. Contacting Us

If you have any questions about this Privacy Policy, our privacy practices, or regarding information on or the correction, blockage or deletion of data, please contact us using the online form (https://littlenoah-s.com/en/contact/).

For residents of the EEA and the UK, the following shall also apply:

For data protection matters, we have appointed Bird & Bird GDPR Representative Services SRL as our representative in the EEA and Bird & Bird GDPR Representative Services UK as our representative in the UK.

You can contact them by email at the addresses listed below. Your message will be forwarded to appropriate members of their data privacy teams.

EEA Residents: EUrepresentative.Cygames@twobirds.com
UK Residents: UKrepresentative.Cygames@twobirds.com