ZENONZARD PRIVACY POLICY

Bandai will collect personal information from Users from a variety of sources, including information we collect directly from Users within the Service, on the Competition Website (e.g. when you contact Bandai), through Google Forms, and information we collect from other sources.

Bandai will process the following information from Users of the Service:

(a) Information related to User's device

• i. Android: Android ID and Advertising ID
• ii. iOS: IDFV (Identifier For Vendor) and IDFA (Identification For Advertisers)

[Acquisition Method]
The information is automatically provided to Bandai when User downloads the Service to his/her own device.

[Purposes of Use]
To allow Bandai to identify when User is using the Service.

(b) Information related to User

• i. Player ID
• ii. IP address
• iii. Application activity history related to the Service
• iv. Payment history

[Acquisition Method]
Automatically acquired from User while using the Service.

[Purposes of Use]
For account management and identification of User accessing the Service.

(c) Information related to settlement of payments

• i. Receipts from various platforms, including whether payment on the item purchased by a user has been made or not.

[Acquisition Method]
Provided to Bandai through a platform operator (for example, Google or Apple) when User has purchased or obtained any items within the Service.

[Purposes of Use]
In order for Bandai to give User the items which have been purchased by User through various platforms.

(d) User ID

i. User ID is an ID required to back up User's activity on the Service and other data of the Service (the "Play Data"). User ID is assigned by Bandai. When Play Data is backed up, the assigned User ID is automatically linked with User's separate BANDAI NAMCO ID, which is issued and managed by Bandai Namco Entertainment ("BNE"), a group company of Bandai, and hosted on Amazon Web Services. BNE has no access to User's Play Data, although BNE does have access to the User's User ID which is linked to BANDAI NAMCO ID.It should be noted that User’s information may be collected pursuant to BANDAI NAMCO ID’s own privacy policy when User obtains a BANDAI NAMCO ID.

[Acquisition Method]
Acquired by Bandai in the backup process when User backs up the Play Data.

[Purposes of Use]
In order for User to back up the Play Data of the Service.

(e) Information provided to customer support

i. Information provided by User to Bandai (including any third party to which Bandai outsources customer support services to) when User makes inquiries to customer support.

[Acquisition Method]
Provided to Bandai when User makes inquiries to customer support.

[Purposes of Use]
For operation of customer support and for responding to inquiries from User.

(f) Information related to use of the Service and interaction with advertisements

i. Information related to use of the Service ("User Activation Information").

ii. In the event user accesses the Service through advertisements placed by Bandai outside the Service, information related to the media on which such advertisements are placed.
*The information indicated in (i) and (ii) above will be stored together as associated information where the information indicated in (ii) above is obtained.

[Acquisition Method]
Automatically provided to Bandai using software from Adjust Inc. which is integrated into the Service’s application.

(*) Please consult the privacy policy of Adjust Inc. for further details (https://www.adjust.com/terms/privacy-policy/).

[Purposes of Use]
For measurement of advertising effectiveness and verification/improvement thereof.

We do not currently respond to web browser “do not track” signals or other mechanisms that provide a method to opt out of the collection of information across the networks of websites and online services in which we participate. For more information, visit www.allaboutdnt.org.

(g) Information relating to participation in Competitions

i. IP address

ii. User name

iii. Email address

iv. Information relating to participation in Competitions

v. Battle record

vi. Information relating to User's hosting a Competition

vii. Users country of Residence

viii. Player ID

ix. Application activity history

x. Play log within the game

[Acquisition Method]
Items i. to viii. are collected either directly from the User on the Competition Website or via Google Forms or by the User navigating the Competition Website. Items viii, ix and x are automatically acquired from the User whilst using the Service and participating in Competitions.

[Purposes of Use]
To allow the User to participate in, host, and vote in Competitions including:

i. For identification of a User participating in a Competition or using the Competition Website.

ii. For login authentication to the Competition Website.

iii. For managing the progress of a Competition.

iv. To display the User name on the Competition Website showing Competition information.

v. For posting aggregation results to the Competition Website and tournament results news.

vi. For posting User Competitions on the Competition Website or Competition result news.

vii. For contacting the User for the purpose of running Competitions and advertising the Service.

viii. To allow Bandai to select Users to participate in certain Competitions.

ix. To allow Users to vote in certain Competitions and provide rewards to Users who win voting predictions.

We must have a legal basis to process User's personal information. In most cases the legal basis will be one of the following:

(a) to fulfil our contractual obligations, for example to provide Users with access to and use of ZENONZARD; or

(b) to meet our legitimate interests, for example to respond to inquiries that Users make to customer support.

A description of the ways we intend to use User's personal data and the legal grounds on which we will process such data follows. We have also explained what our legitimate interests are where relevant.

Purpose/Activity	Type of Data	Lawful basis for processing
To identify Users when using the service.	Information related to User's device. i. Android: Android ID and Advertising ID ii. iOS: IDFV (Identifier For Vendor) and IDFA (Identification For Advertisers)	Performance of a contract; necessary for our legitimate interests for running our business, provision of administration and IT services, network security, to prevent fraud.
To manage User's account.	Information related to User's account. i. Player ID ii. IP address iii. Application activity history related to the Service iv. Payment history	Performance of a contract; necessary to comply with a legal obligation; necessary for our legitimate interests to keep our records updated and to study how customers use our products/services .
To give User the items which have been purchased by User through various platforms.	Information related to settlement of payments. i. Receipts from various platforms, including which item a user has purchased and whether payment on the item has been made or not.	Performance of a contract; Necessary for our legitimate interests to recover debts owed to us and provide items purchased by User to User.
To back up User play data.	Information related to User's device; information related to User's account. i. User ID.	Performance of a contract; Necessary for our legitimate interests for running our business, provision of administration and IT services, network security, to prevent fraud.
To respond to inquiries from User and operate customer support.	Information provided to customer support. i. User name ii. User ID iii. User contact details iv. User payment card information (if payment is made by credit card)	Necessary for our legitimate interests to respond to customer inquiries and improve our services; necessary to comply with a legal obligation.
To measure advertising effectiveness and verification/improvement thereof.	Information related to use of the Service and interaction with advertisements.	Necessary for our legitimate interests to measure advertising effectiveness and improve our services.
To allow Users to participate in, host and vote in Competitions (see further details in section 1(g) above).	i. IP address ii. User name iii. Email address iv. Information relating to participation in Competitions v. Battle record vi. Information relating to User's hosting a Competition vii. User's country of residence viii. Player ID ix. Application activity history x. Play log within the game	Necessary for our legitimate interests in allowing Users to participate in and vote in Competitions; Performance of a contract.

When we process personal information to meet our legitimate interests, we put in place robust safeguards to ensure that User's privacy is protected and to ensure that our legitimate interests are not overridden by a User's interests or fundamental rights and freedoms.

We may obtain User's explicit consent to collect and use certain types of personal information when we are required to do so by law (for example, in relation to our direct marketing activities, or when we process sensitive personal information). If we ask for User's consent to process User's personal information, User may withdraw consent at any time by contacting us using the details at the end of this privacy notice.

Bandai may disclose or provide information it has acquired about Users to a third party in the following cases:

(a) If consent is given by User.

(b) Service providers. If any work such as payment processing, data analysis, competition management, e-mail transmission, hosting services and management, and customer service relating to the Service and any marketing support work of Bandai are outsourced to a third party, User's information will be disclosed and provided to such third party in connection with such outsourcing. For example, our partner JCG Co., Ltd. assists us with managing our Competitions and JCG Co., Ltd. will be responsible for managing the Competition Website.

(c) Disclosure for Cooperation with Third-Party Service. Bandai will disclose User information to third parties in order to link the Service with the services provided by a third party (e.g. Google or Apple) including providing User authentication information.

(d) Disclosure to Third-Party Advertisers. Bandai will disclose and provide User’s device information, etc. to third-party advertisers for advertising or marketing purposes such as analyzing User’s usage, demographic analysis and web analysis.

(e) Group companies. Bandai works closely with other business and companies that fall under the Bandai family. We may share User's User ID with our Group Company, Bandai Namco Entertainment for internal processes, including saving User's Play Data.

(f) Disclosure pursuant to Laws, Regulations, etc. Bandai may disclose User's information to law enforcement agencies, courts, regulators, government authorities or other third parties where it is necessary to comply with a legal or regulatory obligation, or otherwise protect Bandai's rights or the rights of any third party.

(g) Disclosure due to Reorganization or Business Transfer. There are some cases where, due to a merger or company split or other reorganization and transfer of business related to the Service, disclosure and provision of all or part of User’s information is required to the extent necessary for such reorganization and transfer.

Because we operate as part of a global business, the recipients referred to above may be located outside the jurisdiction in which Users are located (or in which we provide the Services). See the section on "International Data Transfer" below for more information.

Bandai has implemented reasonable, technical and physical measures to prevent loss, theft, misuse, unauthorized access, leakage, tampering and destruction of User’s information including encryption of data during data transfer.

Subject to local law, Users may have certain rights regarding their personal information.

For example, if Users are based in the European Union and certain other countries, Users may have the following rights:

(a) Access – request a copy of User’s data and information relating to how it is processed

(b) Rectify – request any inaccuracies in the data we hold about a User be corrected

(c) Erasure – request that we erase User’s data from our records

(d) Restrict – request that User’s data is no longer processed by us

(e) Object – object to certain ways that we process User’s data

(f) Transfer – request that User’s data be shared with a third party

(g) Withdraw User consent – where we are relying on User’s consent to process a User’s data, then User can withdraw that consent at any time

(h) Lodge a complaint – User may be entitled to lodge a complaint with User’s local data protection authority.

Please note that some of these rights are not absolute and there may be certain circumstances where Bandai is unable to fulfil a request. Bandai may confirm User’s identity when responding to User requests.

To exercise any rights, please contact us on the details set out in the 'Contact details' section of this Policy below.

We may collect the following categories of personal information from and about Users:

(a) Identifiers, such as User ID, player ID, IP address advertising identifiers for Android and iOS devices, and email address;

(b) Commercial information, such as payment history and receipts from various platforms;

(c) Internet or other electronic network activity, such as activity history related to the Service, information related to activation and use of the Service and information on User reaction to advertisements shown during the course of use of the Service; and

(d) Geolocation information, such as a User’s country of residence.

Categories of personal information disclosed for our business purposes	Categories of third parties to whom this information was disclosed
Identifiers	Platform providers Cloud-storage providers Game administrators Competition administrators
Commercial information	Platform providers Competition administrators
Internet or other electronic network activity	Mobile measurement service providers Competition administrators
Country of Residence	Competition administrators

Bandai does not “sell” consumers’ personal information (as that term is defined in the California Consumer Privacy Act).

California law also grants its residents certain rights regarding the collection and use of their personal information. Subject to certain limitations, California residents have the following rights:

(a) Right to know. User has the right to know and request information about the categories and specific pieces of personal information we have collected about the User within the last 12 months, 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. User also has the right to know if we have sold or disclosed User’s personal information.

(b) Right to delete. User has the right to request the deletion of User’s personal information, subject to certain exceptions.

(c) Right to non-discrimination. User has the right to not be discriminated against for exercising any of the above-listed rights. We may, however, provide a different level of service or charge a different rate reasonably relating to the value of a user’s personal information.

California residents that would like to exercise any of the above rights, may submit a request at or call us at +81 098-866-5472. Please note that we may require additional information from a User in order to honor a request, and there may be circumstances where we will not be able to honor a request. For example, if a User requests deletion, we may need to retain certain personal information to comply with our legal obligations or other permitted purposes. We will only use personal information provided in a verifiable consumer request to verify a User’s identity or authority to make the request. If a User is submitting a request through an authorized agent, the authorized agent must provide us with the User’s signed written permission stating that the agent is authorized to make the request on the User’s behalf. We may also request that any authorized agents verify their identity and may reach out to a User directly to confirm that the User has provided the agent with permission to submit the request on the User’s behalf.

Finally, Users who reside in California and have provided their personal information to us, may request information once per calendar year about our disclosures of certain categories of their personal information to third parties for the third parties’ direct marketing purposes. Such requests must be submitted to us at the following.

WThe Service is not intended for children under the age of sixteen (16), and Bandai will not knowingly obtain personal information from children under the age of sixteen (16). In the event that Bandai has obtained personal information from a child under the age of sixteen (16) Bandai will take appropriate measures to delete such information promptly.

We will keep User personal information for as long as we have a relationship with User. Once our relationship with User has come to an end, we will retain User’s personal information for a period of time that enables us to:

(a) maintain business records for analysis and/or audit purposes;

(b) comply with record retention requirements under the law;

(c) defend or bring any existing or potential legal claims; and

(d) deal with any complaints regarding the services.

We will delete User personal information when it is no longer required for these purposes. If there is any information that we are unable, for technical reasons, to delete entirely from our systems, we will put in place appropriate measures to prevent any further processing or use of the data.

User personal information may be transferred to, stored and processed in a country that is not regarded as ensuring an adequate level of protection for personal information under applicable laws (such as those in the European Union).

We have put in place appropriate safeguards (such as contractual commitments) in accordance with applicable legal requirements to ensure that User data is adequately protected. For more information on the appropriate safeguards in place, please contact us at the details below.

If you have any questions regarding this Policy or our processing of User personal information related to the Service, please contact us at +81 098-866-5472 (inquiry form).

Our Data Protection Officer can be contacted at zenonzard-dpo@ml.carddass.com.

Bandai may change the Policy from time to time. If we update this Policy, we will notify you by posting a new Policy on this page. If we make any changes that materially change the ways we process or protect User information, we will provide additional notification of the changes.