Privacy Policy

TOMIKUNI TSUSHO CO., LTD. (hereinafter the "Company") operates this mini-game and its related services (collectively, the "Service") on the TikTok platform. This Privacy Policy sets out how the Company collects, uses, shares, and otherwise processes personal information of users in connection with the Service.

This Policy is prepared in compliance with the Act on the Protection of Personal Information of Japan (the "APPI") and related guidelines. Please review this Policy carefully before using the Service.

1. Entity Handling Personal Information

TOMIKUNI TSUSHO CO., LTD.
Address: 1-3-5-203 Higashi Shinsaibashi, Chuo-ku, Osaka, Japan

2. Personal Information Protection Manager

The Company has appointed a Personal Information Protection Manager responsible for overseeing the proper handling of personal information. For inquiries regarding the handling of personal information, please contact the support desk listed at the end of this Policy.

3. Categories of Personal Information We Collect

The Service is a mini-game running on the TikTok platform. The Company does not, as a matter of principle, collect biometric information (such as face or voice prints), contacts (device address book), clipboard content, precise location data, health information, or other sensitive information that is not necessary to provide the game.

(1) Information obtained through TikTok account integration

• A user identifier issued by TikTok to uniquely identify your account
• Nickname and profile picture
• Public profile information within the scope you have authorized

(2) Information generated through gameplay

• Game progress, scores, playtime, item inventory, and leaderboard display name
• In-game action history, stage completion records, and feature usage

(3) Device and connection information

• Device model, OS type and version, screen size, language setting, and timezone
• IP address, connection type, and advertising identifier (which can be reset or disabled in your device settings)
• Crash logs and performance-related telemetry

(4) Purchase information

• In-game purchase history (date, item purchased, amount, and confirmation of payment completion)
• Payments are processed through TikTok's payment system or the app store through which you access the Service. The Company does not directly receive or store credit card numbers.

(5) Information you provide when contacting support

• Information submitted via support forms or email (email address, user ID, description of the issue, screenshots, etc.)

4. How We Collect Information

We collect the information described in Section 3 through the following lawful means:

• At TikTok account linkage, through TikTok's authentication and authorization mechanism.
• Automatically through the Company's servers or embedded SDKs as you play, use features, or make purchases.
• Directly from you when you voluntarily submit a support request or other communication.
• We do not obtain personal information from third parties through unauthorized means.

5. Purposes of Use

We use personal information only within the scope of the following purposes, and we have implemented safeguards to prevent use beyond these purposes:

1. Providing, maintaining, managing, authenticating, and signing you into the Service.
2. Storing and displaying game progress, scores, leaderboard rankings, and in-game items.
3. Responding to user inquiries and support requests, and verifying your identity.
4. Preventing unauthorized use, detecting cheating or abusive behavior, and protecting the safety and integrity of the Service.
5. Analyzing usage patterns, improving quality, and developing new features (including aggregated or anonymized statistics).
6. Serving advertisements within the Service or elsewhere, measuring ad effectiveness, and delivering personalized advertising.
7. Sending notices regarding changes, suspensions, or termination of the Service.
8. Complying with applicable laws and regulations, and protecting the legitimate rights of the Company, users, or third parties.

If we change the purposes of use, we will notify you in advance or publish the revised purposes through the Service or our designated webpage.

6. Third-Party Provision and Outsourcing

(1) Except in the following cases, the Company will not provide personal information to third parties without your consent:

• You have given your consent.
• Disclosure is required by law.
• Disclosure is necessary to protect a person's life, body, or property, and your consent is difficult to obtain.
• Disclosure is necessary to promote public health or the sound upbringing of children, and your consent is difficult to obtain.
• Disclosure is necessary to cooperate with a national or local government agency performing its statutory duties, and obtaining your consent would impede those duties.

(2) To achieve the purposes of use, we may outsource all or part of the handling of personal information to a third party. In such cases, we select a contractor with an adequate level of personal information protection, enter into a contract imposing necessary obligations, and supervise the contractor's handling.

(3) The Service may incorporate third-party SDKs (software development kits) for advertising delivery, ad measurement, and usage analytics. These SDKs may transmit advertising identifiers, device information, and usage data to the relevant third parties. For details on the information transmitted and how such third parties handle that information, please refer to the privacy policies published by those service providers.

• To opt out of personalized advertising, you may limit ad tracking in your device settings (on iOS: Settings > Privacy & Security > Tracking; on Android: Settings > Privacy > Ads).

7. Joint Use

The Company does not currently jointly use personal information with any third party. If we commence joint use in the future, we will in advance notify or publish the scope of joint users, the items used, the purposes of use, and whether a management responsibility lies with the joint users.

8. Cross-Border Transfers

As part of operating the Service, the Company may transfer personal information to a third party located outside Japan. In such cases, we will comply with the procedures required by the APPI, including obtaining your consent, notifying you of the receiving country and the personal information protection system in that country, and implementing measures to ensure an adequate level of protection. If you request specific details about a recipient, the items transferred, or the purpose of the transfer, we will respond without delay.

9. Security Management Measures

The Company takes the following measures to prevent leakage, loss, or damage of personal data and to otherwise maintain its security:

1. Establishment of a basic policy and internal rules governing the handling of personal information.
2. Access controls, least-privilege permissions, and employee training.
3. Encryption in transit and at rest, and necessary countermeasures against unauthorized access and malware.
4. Oversight of contractors and preparedness for incidents.
5. Clear assignment of responsibility through the appointment of a Personal Information Protection Manager.

10. Retention Period for Retained Personal Data

The Company does not retain personal information beyond the period necessary to achieve the purposes of use. The general approach is as follows; information that is no longer needed will be deleted or anonymized through appropriate means:

• Gameplay data and account information: while you use the Service, plus up to approximately one year after cessation of use for support and reconciliation purposes.
• Purchase records: as required by law (up to approximately seven years).
• Support records: up to approximately three years after the relevant inquiry is closed.
• Cookies and advertising identifiers: as determined by the applicable SDK or platform.

If you wish to request deletion of specific data, please contact the support desk below.

11. Your Rights (Disclosure, Correction, Suspension, Deletion, etc.)

You have the following rights with respect to the personal data we retain about you:

1. Request for disclosure.
2. Request for notification of the purpose of use.
3. Request for correction, addition, or deletion.
4. Request for suspension of use, erasure, or suspension of provision to third parties.

To exercise any of these rights, please contact the support desk below. After verifying your identity, we will respond within the period prescribed by law. You may be asked to provide identifying information (such as your TikTok user ID and registered email address).

We may decline all or part of a request in the following cases; if we do, we will explain the reason:

• We are unable to verify that you are the principal or an authorized agent.
• Required documentation is incomplete.
• Compliance would violate laws or regulations, or would be necessary to protect the life, body, or property of an individual.
• We have already taken the relevant measure.

Complaints and consultations may also be directed to the support desk.

12. Handling of Information of Minors

The Service is intended for users aged 13 or older (or the applicable minimum age for consenting to digital services in your country or region). Users under 13 are not permitted to use the Service. If a minor under the age of majority uses the Service without the consent of a parent or legal guardian, we will, upon request by the guardian, suspend or delete the account and the associated personal information. We recommend that guardians carefully monitor any in-game purchases made by minors.

13. Changes to This Policy

The Company may revise this Policy without prior notice as needed to improve the handling of personal information, to comply with changes in laws and regulations, or for other operational reasons. In the event of material changes, we will provide a clear notice within the Service or on our designated webpage. The revised Policy takes effect from the time of publication.

— End of Privacy Policy —