Last Updated: 2022-09-09

1. Ⅰ. Collection of Information

   The information we collect from you depends on the context in which you provide it and use our Services. We collect the following categories of information: identifiers, internet or other similar network activity, commercial information, geolocation data, and inferences drawn from other personal information. More details about these categories of data are provided below, and the business and commercial purposes for which we collect personal information is described in the Use of Information section.

   • 1. Information You Provide to Us

     We collect information you provide directly to us. For example, we collect information when you create an account, interact with other users, upload images to our servers, request customer support, sign up to receive newsletters, participate in surveys or otherwise communicate with us. The types of information we may collect include your username, password, email address, photos, and any other information you choose to provide.

   • 2. Information We Collect Automatically When You Use the Services

     When you access or use our Services, we automatically collect information about you, including:

     1. a) Usage Information

        We collect information about your use of our Services, including gaming service ID, levels completed, game scores, time spent using our Services, and other game play information.

     2. b) Log Information

        We log information about your use of our Services, including your browser type and language, access times, pages viewed, your IP address and the website you visited before navigating to our Services.

     3. c) Hardware Information

        We collect information about the computer or device you use to access our Services, including the hardware model, operating system and version, browser mobile network information, list of other ACES mobile applications installed on the device, MAC address, IP address International Mobile Equipment Identity (“IMEI”) number and other unique device identifiers made available by the operating system of your device.

     4. d) Location Information

        We may collect information regarding the geographic location of your device each time you use the Services provided on iOS or Android platforms or otherwise consent to the collection of this information. You may withdraw consent for the collection of platform provided location data using the settings on your device. Your location is stored for the period specified in the Services before collection.

     5. e) Information Collected by Cookies and Other Tracking Technologies

        We use various technologies to collect information (which may include personal information), and this may include sending cookies to your computer or mobile device. Cookies are small data files stored on your computer hard drive or in device memory that help us to improve our Services and your experience, see which areas and features of our Services are popular and count visits.

     6. f) Profile Information

        We create profiles based upon your preferences, characteristics, behavior and other information from your use of the Services, and with your consent, we combine that information with information from other sources.

   • 3. Information We Collect From Third Parties

     We may also obtain information from other sources as far as it is necessary to perform our Services, and combine that with information we collect through our Services. For instance, we may collect game ranking and achievement status from your console or mobile operating system game center application. We also obtain publicly available information from social media monitoring service platform. If you create or log into your ACES account through a third-party platform (such as Facebook or Twitter), we will have access to certain information from that platform, such as your name, birthday, and profile picture, in accordance with the authorization you give to such platform. Additionally, when you complete in-app purchases, we may collect information about you from the provider of your device operating system when they process the purchases on our behalf. Please note that we do not receive your payment method information from the operating system providers. In other cases, we will ask you to authorize us to collect, store, and use personal information from third parties.

2. Ⅱ. Use of Information

   We only collect, store and use your information if you have consented to it or, to the extent that it is necessary (i) for the performance of your agreement with us; (ii) to comply with our legal obligations; or (iii) for the purpose of our legitimate interests, including operating, evaluating and improving our global business. We have carefully balanced our legitimate business interests against your interests. Please contact us using the contact details provided below if you have questions on this balancing of interests.

   We (or a third party data processor on our behalf) may collect, store and use information about you for the following purposes for the periods necessary to achieve such purposes:

   Legal Basis	How We Use Your Information
   Performance of Your Agreement with Us	Provide our Services	Provide and deliver the products and services you request, process transactions and send you related information	Register you for an account on our Services and assist in the management of your account	Respond to your comments, questions and requests and provide customer service	Send you technical notices, updates, security alerts and support and administrative messages	Process and deliver contest entries and rewards promoted by ACES
   Legitimate Interest	For any purpose required or authorized for us to comply with our legal and regulatory obligations	Monitor and analyze trends, usage and activities in connection with our Services	Detect, investigate and/or prevent fraudulent, unauthorized or illegal activity	Obtain parent or legal guardian verification	Provide contextual in-Service advertisement	Monitor, analyze and develop our brands on social media by using social media monitoring services
   Consent	Communicate with you about products, services, offers, promotions, rewards, and events offered by ACES and others, and provide news, information and other marketing materials that we think will be of interest to you	Link or combine your data with other Services and with information we get from other sources to analyze service and monetization trends, create profiles of categories of users, create new games and services, and perform other analytics	Link or combine with information we get from our advertising partners to help understand your needs and provide you with better in-Service personalized ads; serve in-Service advertisements that might be of interest to you; monitor and analyze trends, usage and activities in connection with the advertisements and our Services; creating profiles of types of Service users by combining your data with information from advertising partners	Creating profiles of types of users by combining your data with information from our advertising partners, providing the data to our group companies, ad agencies and ad platforms to target advertisements of our (and our group company) games and services to you outside of this service, and otherwise performing advertising analytics and performance metrics	For any other purpose for which you provided the information

3. Ⅲ. Sharing of Information

   We do not share, transfer or otherwise exchange your personal information with third parties, unless required for the provision of our products or services, otherwise as permitted or required by law, or if you have given us express consent. We do not sell your personal information to third parties.

   In compliance with the aforementioned, we may share information about you as follows or as otherwise described in this Privacy Policy:

   1. a) With other users if you choose to participate in the interactive areas of our Services, such as multiplayer, chat, or sharing features (the use of personally identifiable data (such as your full name) as a username in our Services is strictly prohibited);

   2. b) With our employees, affiliates, related companies, vendors, consultants and other third party service providers who need access to such information to carry out work on our behalf (including, for example, developers, payment processors, website hosting services, or information storage and processing service providers);

   3. c) In response to legal process or a request for information if disclosure is in accordance with, or as otherwise required by applicable law, rule, or regulation (including, for example government or regulatory bodies, law enforcement, or courts of law);

   4. d) If we have reasonable grounds to believe your actions are inconsistent with our user agreements or policies, or to protect the rights, property and safety of ACES, our users or others and we consider our legitimate interests in disclosing your personal information to third parties (such as courts or attorneys) to weigh your interests in the specific case;

   5. e) In connection with any merger, sale of company assets, financing or acquisition of all or a portion of our business to another company (provided we have a legal basis); and

   6. f) With your consent or at your direction.

4. Ⅳ. Advertising and Analytics Services Provided by Others

   We may allow others to provide analytics services on our behalf and to serve advertisements within our Services. These entities may use technologies to automatically collect information about your device and your use of our Services, including IP address, device ID, time spent on pages within our Services, and links clicked within our Services. This information may be used by us and others to, among other things, maintain, improve, and analyze the functioning of our Services and deliver contextual or targeted advertising that may be of interest to you. The use of your information by these third parties is covered by their respective privacy policies, and we do not control and are not responsible for the privacy practices of third parties.

   Some of our Services will, with your prior consent, combine game play and analytic information with information collected from other Bandai Namco Entertainment games, games from our group companies, and other third party sources to analyze game and monetization trends, create profiles of categories of players, create new games and services, and perform other analytics. With your consent or at your direction, we also use certain information collected through our games for advertisement targeting outside of the game. This includes creating profiles of types of players by combining your data with information from our advertising partners, providing the data to our ad agencies and ad platforms to target advertisements of our (and our group company) games and services to you outside of this game, and otherwise performing advertising analytics and performance metrics.

5. Ⅴ. Social Sharing Feature

   The Services may offer social sharing features or other tools, which let you share actions or link the Services with social media. The use of such features enables the sharing of information with your friends or the public, depending on the settings you establish with the social media platform. For more information about the purpose and scope of data collection and processing in connection with social sharing features, please visit the privacy policies of the social media platforms.

6. Ⅵ. Security

   We take reasonable technical and organizational measures to help protect information about you from loss, theft, misuse and unauthorized access, disclosure, alteration and destruction. However, no transmission over the internet can ever be guaranteed secure so we cannot guarantee the security of any personal information that you transfer over the internet to us.

7. Ⅶ. Storing and deleting data

   Personal information collected through the Services is being stored and deleted in compliance with privacy requirements. All data will be de-identified or deleted if no longer required for the purposes mentioned above, unless further retention is required by law.

8. Ⅷ. International Transfers

   Personal information that we collect from you is usually transferred, stored and processed in Japan. Please be aware that we may transfer your personal information to locations outside of Japan that offer the same level of data protection as Japanese laws (and GDPR for EU users) and outside of your country which may not offer the same level of data protection as your country’s laws. In addition, we may store your personal information on a server installed outside Japan by us (and our group companies) or by our business partners. However we do disclose your personal information to third parties located overseas after reviewing the privacy regulations in the country or region where your personal information is stored or handled, we take such steps as are required in the circumstances to ensure it is used in accordance with applicable laws.

9. Ⅸ. Third Party Sites

   Our Services may contain links to other websites or services operated by third parties. Please note that this Privacy Policy applies only to our Services and we cannot be responsible for personal information that third parties may collect, store and use through their website. You should always read the privacy policy of each website you visit carefully.

10. Ⅹ. Push Notifications/Alerts

    ACES may send push notifications or alerts to your device. You can deactivate these messages at any time by changing the notification settings on your device. ACES will send push notifications or alerts with promotional content only after your prior opt-in to receiving such messages on your device.

11. Ⅺ. Data Protection Rights

    You, and your legal guardian if you are a minor, have certain data protection rights under applicable law. Your rights under applicable law may include:

    1. a) Access to the personal information we process about you as well as the right to data portability,

    2. b) The right to have personal information corrected or erased,

    3. c) The right to restrict the processing of your personal information

    4. d) The right to withdraw your consent at any time for consent we have obtained from you, although this will not affect the lawfulness of the processing prior to the withdrawal.

    5. e) You also have the right to object, at any time, to the processing of your personal information which is based on ACES’s legitimate interests.

    6. f) Where we process your personal information for direct marketing purposes, you have the right to object at any time to such processing, including for profiling purposes to the extent that it is related to direct marketing. If you object to processing for direct marketing purposes, we will no longer process your personal information for such purposes. In that case we may still send you transactional or relationship messages, but only about our ongoing business relations.

    7. g) The right to not be discriminated against for exercising these rights.

    To exercise these rights, you should make a request using our contact details set out below. If you are not satisfied with the way we handle your request, and your country of residence has a supervisory authority, you may lodge a complaint with such supervisory authority in your country of residence. We do not provide different levels of service if you exercise these rights.

    However, if you request that we delete or cease collecting information which is necessary to ensure adequate functioning of the Services, you may not be able to use all or some parts of our Services.

12. Ⅻ. Contact

    If you have any questions about this Privacy Policy or our practices, please contact us at:

    Bandai Namco Aces Inc.
    Shinjuku Sankocho Building,5-15-5 Shinjuku
    Shinjuku-ku, Tokyo 160-0022
    Japan
    https://www.bnaces.co.jp/en/contact/

Last Updated: 2023-02-20

1. Ⅰ. Compliance with Laws and Regulations

   We will comply with all relevant laws and regulations and these Terms and Conditions regarding the acquisition, use, and other handling of personal information.

2. Ⅱ. Use of Personal Information

   We will use personal information only for the following purposes.

   - Contacting the individual applicant for employment

   - Selection materials to determine if the applicant meets the recruitment requirements

   - Statistical data for future recruitment activities

   - Basic materials for employment management after employment decision is made

3. Ⅲ. Retention Period

   We will set the retention period of personal information to the extent necessary for the purpose of use, and will delete or dispose of personal information in an appropriate manner without delay after the retention period has elapsed.

4. Ⅳ. Security Control Measures

   We will take necessary and appropriate security control measures to prevent leakage, loss, or damage of personal information, and will strive to improve such measures.

5. Ⅴ. Supervision of employees and contractors

   1. A person responsible for the handling of personal information shall be appointed and that person shall manage personal information appropriately.

   2. Only authorized and properly trained officers and employees of the Company shall handle personal information to the extent necessary for the purposes of use.

   3. Personal information may be entrusted to a third party to the extent necessary for the purposes of use stipulated herein. In such cases, we will oblige the third party to handle personal information appropriately by contract or other means, and supervise the third party as necessary and appropriate.

6. Ⅵ. Disclosure to Third Parties

   We will not disclose or provide personal information to third parties except in the following cases.

   1. When the individual concerned has given his/her consent

   2. When the information is disclosed in a manner that the individual cannot be identified

   3. When it is necessary to provide personal information in accordance with the Personal Information Protection Law or other laws and regulations.

   4. when the person to whom the personal information is provided does not fall under the category of a third party under the Personal Information Protection Law (e.g., an outside contractor).

7. Ⅶ. Contact

   If you have any questions about this Privacy Policy or our practices, please contact us at:

   Bandai Namco Aces Inc.
   Shinjuku Sankocho Building,5-15-5 Shinjuku
   Shinjuku-ku, Tokyo 160-0022
   Japan
   https://www.bnaces.co.jp/en/contact/

8. Ⅷ. Request for Disclosure of Personal Information

   For requests for disclosure, etc. (disclosure, notification of purpose of use, correction, suspension of use, deletion), please fill in the necessary items on the form "Request Form for Disclosure of Personal Information" and send it by mail to the address below, along with a copy of your driver’s license, passport, or health insurance card (if your permanent address or medical record is included, please make a copy without the permanent address or medical record).

   Please send one of the following by mail, enclosing one of the following.

   In addition, for requests from a legal representative or agent, please enclose the required documents listed in the "Personal Information Disclosure Request Form".

9. Ⅸ. Personal Information Disclosure Request Form

   1. request form for disclosure of personal information and notification of purpose of use (156KB)

   2. Request Form for Correction, etc. of Personal Information (152KB)

   3. request form for suspension of use of personal information (152KB)

   *Adobe Reader is required to view PDF documents.

10. Ⅹ. Fees and charges

    A separate fee will be charged for the disclosure of personal information to the person in question and for notification of the purpose of use. There is no charge for requests for correction, suspension of use, or deletion.

    Fee: 800 yen per request

    Payment method: Please send a fixed-sum money order (issued by a post office) together with the "Personal Information Disclosure Request Form".

11. Please note that we may not be able to respond appropriately to your request for disclosure of personal information if there are any missing or incorrect information on the Personal Information Disclosure Request Form.

    Personal information provided by the person in question on the Personal Information Disclosure Request Form will be used for the purpose of responding appropriately to the request for disclosure, etc., and will be kept in strict confidence for a certain period of time.

    Please note that the request form and attached documents for which identification cannot be confirmed will not be returned.

12. Ⅺ. Modification of Terms and Conditions

    We reserve the right to modify these Terms and Conditions at any time.