This EULA refers to the distribution and retail by Kotobuki Solution Co., Ltd. (hereinafter referred to as 'the Company') of an application or applications for personal computer systems, gaming console systems and devices compatible with iOS, Android™ or any other OS (hereinafter referred to as 'Content'), where the Company possesses the distribution and retail rights for the Content. This EULA also refers to any distribution and retail services (hereinafter referred to as 'Distribution Services'), operated by the Company or any other parties including but not limited to Apple Inc. nor Google LLC (hereinafter referred to as 'the Operator'), through which the Content is distributed or sold. This EULA defines the encompassing terms and represents the agreement concerning usage of the Content and of the Distribution Services.
This EULA shall not apply to the following Distribution Services, websites and Content and separate terms and agreements shall apply. In order to use the following services, please refer to each EULA and term. However, each EULA and term is available only in Japanese.

【Distribution Service and Websites】

• KEMCO Empire (for docomo, KDDI, SoftBank):　EULA
• KEMCO Space 200:　EULA

【Content】

• Android apps provided via KEMCO Empire for Sugotoku:　EULA and Privacy Policy for Sugotoku established by NTT DOCOMO, INC. shall apply.

By consenting to this EULA, the user of the Content (hereinafter referred to as 'the Customer') shall be granted usage rights for the Content (a Usage License) as specified in this EULA. When using the Content, the Customer must agree to and comply with this EULA in its entirety, and in addition must agree to and comply with any other related Agreements of, including but not limited to any Distribution Services, communication line, mobile phone device employed by the Customer, means of payment employed by the Customer. The Customer should be sure to read this EULA carefully before using the Content or the Distribution Services. Use of the Content itself and/or the Distribution Services for the Content shall be taken to indicate consent to this EULA in its entirety.

1. All rights, including copyright, etc., relating to Content provided by means of the Distribution Services, and to any and all related data, shall be retained by the Company or any third parties shown in the Content.
2. Without prior consent from the Company, the Customer shall not reproduce, duplicate, modify, accumulate or transfer the Content or any related data, and nor shall the Customer engage in any other acts which infringe upon any of the rights, including copyright, retained by the Company or any third parties shown in the Content.

1. The Usage License grants to the Customer the right to use the Content, subject to the following conditions and restrictions.
1. The Customer shall be granted the right to use all functions and operations originally built in to the Content.
2. The Customer shall use the Content in accordance with the method of use explained within the Content.
3. The Customer shall use the Content in accordance with any method of use specified separately by the Company for the Content.
4. The Customer shall use the Content in a way that does not constitute a violation of this EULA or of any other related Agreements.
5. The Customer shall use the Content in a way that does not constitute a violation of any other restriction specified separately by the Company.
6. The Customer shall use the Content for the purpose intended by the Company.
2. The Customer shall not intentionally use the Content in any way which would constitute a violation of the conditions and restrictions of the Usage License.
3. The Usage License is granted to the Customer based on the acceptance of the EULA by the Customer who will use the Content, and as such, the Usage License may not be transferred to any other party.

1. When using the Company's Content, the Customer shall, in addition to accepting the terms of this EULA, promptly pay any fees where such fees are specified. By doing so, the Customer shall be granted a Usage License to the Company's Content.
2. The Company shall treat all fees received as payments made with valid intention by the Customer, and with the Customer having consented to the terms and conditions of this EULA. Payments made by a third person having assumed the identity of the Customer or payments resulting from mistakes in operation shall be regarded as within the bounds of responsibility of the Customer, and the responsibility for payment shall lie with the Customer.
3. With regard to Content, the ability to cancel an order, and the availability of refunds, exchanges, and re-downloads shall be determined according to the policies and capabilities of the Distribution Service. In the case that order cancellations, refunds, exchanges, and re-downloads are not available according to the policies of the Distribution Service, or in the case that order cancellations, refunds, exchanges, and re-downloads are outside the capabilities of the Distribution Service, in principle the Customer shall not be able to cancel an order, receive a refund or exchange, or re-download, through the Company and/or the Operator.
4. When downloading and using the Content, the Customer may incur separate communication charges and service charges, according to the Customer's telecommunications contract or payment contract. These fees are not included in the Content fee or the Content usage fee, and shall be paid separately by the Customer as specified in the applicable contract.
5. All monies paid by the Customer to the Company shall be collected on behalf of the Company by a payment collection agent (such as the provider of a Means of Payment, a credit card company, etc.) as set out in the Agreement regarding the medium through which the Content is distributed and/or sold.
6. In the case that any question or dispute between the Company and the Customer arises in connection with the Content usage fee, the Company shall accept the Customer's inquiries in a comprehensive manner. The Customer shall agree not to contact the Operator, a payment collection agent or any other third party before making inquiries with the Company.
7. If a payment is determined to be delayed for reasons attributable to the Customer, the Company shall be able to obtain from the payment collection agent the disclosure of the name, address, payment details, etc., of the Customer.

1. An 'in-app billing system' is an element included in certain Content. If the Customer wishes to use (hereinafter referred to as 'Acquire') these 'restricted elements' (hereinafter referred to as 'Items'), the Customer shall be able to gain use of the Items by following the instructions within the Content and paying any applicable fees by means of a method of payment supported by the Content (hereinafter referred to as a 'Purchase'). This series of actions is referred to as 'in-app billing', and the elements which make in-app billing possible, including all functions, Agreements and Terms of Service, interfaces, etc., are referred to as a whole as an 'in-app billing system'. The in-app billing system includes and encompasses all related elements, such as the functions to Purchase relevant elements within the Content, the web-sites accessed by the relevant functions, the functions of online payment platforms provided by third parties, etc., in addition to the Items themselves within the Content.
2. 'Points' are special Items which when applied permit the use of 'points-supporting Items'. 'Points-supporting Items' are a type of Item, but are different in that they become usable through the application of points rather than through a Purchase. Irrespective of any literal definition or meaning, points are not like a virtual currency or net money, which can be used just like physical money to make payments. Essentially, points are 'the usage rights for a points-supporting Item'. Points have the following characteristics.
3. Points are sold as Items with general names such as '*** point(s)' or '*** ticket(s)', in Content which includes an in-app billing system.
4. Points are specific to individual Content, and cannot be interchanged between Content.
5. At the moment when they are obtained, points grant to the Customer usage rights for a point-supporting Item based on the quantity of points obtained.
6. With regard to the in-app billing system, a financial transaction occurs only in the case that 'the Customer makes a Purchase of an Item from the Company within the Content'. In all other cases, no financial transaction occurs, nor is any financial transaction permitted or accepted, between the Company and the Customer, or between the Customer and a third party.
7. An Item once Acquired cannot be exchanged for any other Item, benefit, service, goods, money, or goods with monetary value, with an effect or value greater than that of the Acquired Item. This applies to exchanges involving the Company, the Customer, or any third party. Furthermore, when points have already been applied, it is not possible to apply those points to any other points-supporting Item. Even to attempt any such improper exchange shall be regarded as a breach of the terms and conditions of this EULA.
8. Acquired Items have their own characteristics. Depending on its individual characteristics, an Acquired Item may be consumed partially or entirely when used within the Content, with the Item being reduced or disappearing (being used up) completely. Furthermore, some Items may have limited periods of validity. When the period of validity of such an Item is exceeded, the Item may become no longer usable, and may disappear. Whether or not an Item is reduced or disappears completely when used is governed by the explanation provided when the Item is supplied. When an Item is reduced or disappears completely when used in accordance with this explanation, this shall be regarded as proper and correct usage and consumption, to which the Customer has given consent.
9. When Acquiring an Item, the Customer shall be deemed to have read carefully any and all explanations (including but not limited to explanations relating to how to use the Item, to whether or not the Item is consumed when used within the Content, to the presence or absence of any period of validity, or the price or quantity of points) and to have Acquired the Item in a proper way having assented to any and all terms and conditions set out in the explanations. With regard to Items, the ability to cancel an order, and the availability of refunds, exchanges, and re-downloads shall be determined according to the policies and capabilities of the Distribution Service. In the case that order cancellations, refunds, exchanges, and re-downloads are not available according to the policies of the Distribution Service, or in the case that order cancellations, refunds, exchanges, and re-downloads are outside the capabilities of the Distribution Service, in principle the Customer shall not be able to cancel an order, receive a refund or exchange, or re-download, through the Company and/or the Operator.

1. The Content may utilize data communication in order to implement various features, including but not limited to implementation of the in-app billing system, online license checking in order to establish whether or not the Content itself has been purchased correctly, User Support, and notifications. The Customer shall consent to this utilization of data communication.

1. KEMCO ID refers to a service which is intended to provide to the Customer, on an individual basis, online functions closely linked to the Content, and which makes use of an email address provided by the Customer at the time of registration as an individual identification information string (hereinafter referred to as 'the ID'). Simultaneously, KEMCO ID also refers to the account service itself, protected by the ID and a password set by the Customer. With regard to the use of KEMCO ID and to the use of any and all functions making use of KEMCO ID, the Customer shall agree to all items within this clause.
2. The Customer has a duty to manage and keep safe his/her KEMCO ID and password for the account. The Customer should change his/her password on a regular basis, and employ a password which is not easily guessable by others. The Company shall bear no liability to provide compensation of any sort for any damage arising from insufficient management and protection of the KEMCO ID and password on the part of the Customer.
3. The Customer's KEMCO ID and any data linked to the KEMCO ID may not be transferred or sold, etc., to any third party.
4. KEMCO ID is used for the 'Safe Save' function available in certain Content. When the communication signal is of sufficient quality and strength, this function creates non-real-time backups of game progress data. These backups are created at set intervals, and stored on the Company's online server. This function is designed to allow the recovery and restoration of game progress data in the case that corruption occurs, and to assist with the transfer of game progress data when the Customer changes devices.
1. With regard to the use of the 'Safe Save' function, the Customer shall be deemed to have fully understood and acknowledged the method of operation and intended purpose of the function. Further, the Customer accepts that in the case that the function is used in a way which does not conform to the method of operation and intended purpose of the function, use of the Customer's KEMCO ID may be suspended or terminated without notice.
2. The Customer acknowledges and accepts that there exists the possibility that because of reasons including but not limited to network trouble, machinery or material trouble, the loss of game progress data created after the most recent backup, etc., all or part of the game progress data, either on the device or stored as backup data online, may be lost. Further, the Customer acknowledges and accepts that even with the use of the 'Safe Save' function, the recovery and restoration of game progress data cannot be guaranteed.

1. If a situation arises where the usage of the Content as intended by the Company is inhibited because of defects in the Content or arising from unintended behavior of the device or platform, etc., or if a situation arises where the Content is able to be used in a way not intended by the Company, then the Company shall take appropriate measures in good faith to deal with the situation. The contact the Company makes with the Customer, by telephone, email, or other methods in order to take measures to deal with the situation, and the measures taken by the Company to deal with the situation having received information supplied by the Customer, shall be referred to as 'User Support'.
2. Any personal information related to the Customer necessary for User Support (name, telephone number, email address, etc.) will be protected according to the provisions of the Company's 'Privacy Policy and Notice' which includes the fundamental policies set out by the Company regarding the protection of personal information (http://www.kemco-games.com/global/privacy.html), and used solely for the purpose of User Support.
3. If a situation arises where the User Support is not needed, inappropriate or impossible to be continued, the Company shall be entitled to deny or cease the User Support demanded by the Customer. Hereunder indicates the examples which may result the denial or cease of the User Support, but not limited to:
1. In case where any violations of this EULA by the Customer is obvious.
2. In case of any conditions which make the proper work of the Content non-guaranteed is obviously indicated and the Customer's usage of the Content is applicable to them.
3. In case where it becomes obvious that the reason of the problem is the intentional operation by the Customer or the change of the usage environment of the Content arose from the Customer's personal situation.
4. In case the problem is impossible or hard to be fixed by the change or modification of the Content.

1. The Company and the Customer shall agree that this EULA shall be entered into between the Company and the Customer only, and not with the Operator, and the Company, not the Operator, is solely responsible for the Content.
2. The Company and the Customer shall agree that the Company shall be solely responsible for furnishing any maintenance and User Support with respect to the Content, as required under applicable law, and that the Operator has no obligation whatsoever to furnish any maintenance and User Support with respect to the Content.
3. The Company and the Customer shall agree that the Company shall be solely responsible for any claims, losses, liabilities, damages, costs or expenses attributable to any failure of the Content to conform to any applicable warranty whether express or implied by law, to the extent not effectively disclaimed. The Customer shall agree that, in the event of any failure of the Content to conform to any applicable warranty, the Customer shall not demand the Operator any special services or functions for the warranty outside the capabilities of the Operator.
4. The Company and the Customer shall agree that the Company, not the Operator, are responsible for addressing any claims of the Customer or any third party relating to the Content or the Customer's possession and/or use of that Content, including, but not limited to: (i) product liability claims; (ii) any claim that the Content fails to conform to any applicable legal or regulatory requirement; and (iii) claims arising under consumer protection or similar legislation.
5. The Company and the Customer shall agree that, in the event of any third party claim that the Content or the Customer's possession and use of that Content infringes that third party's intellectual property rights, the Company, not the Operator, will be solely responsible for the investigation, defense, settlement and discharge of any such intellectual property infringement claim.
6. The Customer shall represent and warrant that the Customer is not located in a country that is subject to a U.S. Government embargo, or that has been designated by the U.S. Government as a 'terrorist supporting' country; and that the Customer is not listed on any U.S. Government list of prohibited or restricted parties.
7. The Company and the Customer shall agree that the Operator, and the Operator's subsidiaries, are third party beneficiaries of the EULA, and that, upon the Customer's acceptance of the terms and conditions of the EULA, the Operator will have the right (and will be deemed to have accepted the right) to enforce the EULA against the Customer as a third party beneficiary thereof.

1. The Usage License granted to the Customer shall become null and void if the Customer fails to comply with the terms and conditions of this EULA. Consequently, the Company shall be able to prohibit the use of the Content by the Customer, and terminate the usage of any and all Distribution Services operated by the Company and User Support provided by the Company. Furthermore, if the Company suffers damages resulting from any failure on the part of the Customer to comply with the terms and conditions of this EULA, the Company shall be able to demand from the Customer compensation equivalent to the cost of the damages.

1. The Customer is not permitted to transfer or assign any of the rights or obligations related to this EULA to any third party.
2. If the Customer suffers damages in the course of using the Content due to grounds attributable to the Company, the Company shall make restitution, the amount of restitution being limited to an amount equivalent to the cost of the usage fee paid for the Content. However, in the case of damages attributable to willful or gross negligence on the part of the Company, such a limit shall not apply.
3. The Customer shall acknowledge that there exist several risks in the course of using smartphone applications (hereinafter referred to as 'Risks'). Further, the Customer shall acknowledge that the Company is not liable for the Risks, and shall disclaim the right to claim compensation from the Company for any damages caused by the Risks. The Risks include, but are not limited to, the proper working of the Content being prevented by an abnormal application execution environment resulting from the installation and/or execution of other applications, data saved by the Content being corrupted irreversibly because of the malfunction of the device (whatever the reason for this malfunction), and some special specifications or defects of the device, firmware and/or operating system causing any or all of the aforementioned situations.
4. In the case that versions of the Content (either identical versions or differing versions of the Content) are distributed and made available for purchase on a number of different Distribution Services, each and all of these versions of the Content shall be regarded as entirely separate merchandise, distributed and made available for purchase on different Distribution Services. As such, the Customer is not able to transfer the Usage License for the Content obtained from one distribution service to a similar version of the Content available on another Distribution Service. In order to use a similar version of the Content available on another Distribution Service, the Customer must obtain a separate Usage License for the Content available on the appropriate Distribution Service. This applies irrespective of the presence or not of functions, such as the 'Safe Save' function provided by the Company, which allow the transfer of data related to the Content between similar versions of the Content on different Distribution Services, and irrespective of the presence or not of any other functions.
5. In the case that any question or dispute between the Company and the Customer arises out of, or in connection with, this EULA or any Content, the Company shall enter into negotiations with the Customer in good faith. If the question or dispute cannot be settled despite these negotiations, then Hiroshima District Court or Hiroshima Summary Court shall have the exclusive jurisdiction of the first instance.
6. This EULA exists in several languages, for the benefit of non-Japanese-speaking Customers. The scope and content of the EULA is the same across all languages. However, if for any reason there exists a contradiction between the scope, terms or content expressed in the Japanese-language version of the EULA and the scope, terms or content expressed in the English-language version of the EULA, then the Japanese-language version shall be deemed to take precedence.
7. The Company reserves the right, without informing the Customer, to update, revise, supplement or terminate this EULA. The Customer should be sure always to check the terms and conditions of the most recent version of this EULA, and to use the Content having consented to the terms and conditions of the most recent version of the EULA in its entirety.
8. Contact about the Content or this agreement from the Company to the Customer shall be done via announcements on the Company's website, in the Content, E-mails or any method which is deemed appropriate by the Company.
9. Contact about the Content or this agreement from the Customer to the Company shall be done via the contact guides set in the Content, the designated contact form on the Company's website or any method which is deemed appropriate by the Company.
10. The Company can, including but not limited to, send, receive or use any sort of information via the Content or the Distribution Services regardless if it is evincible or not. Any other parties concerning to the Distribution Services can also, including but not limited to, send, receive or use any sort of information via the Content or the Distribution Services regardless the Company's intention. All the usages of the information as far as the Company knows are described on the 'Privacy Policy and Notice'. The Customer should be sure to read and assent the 'Privacy Policy and Notice' before using the Content or the Distribution Service operated by the Company.

This Privacy Policy and Notice (hereinafter referred to as the 'Kotobuki Privacy Policy') refers to the policies regarding the protection of personal information by Kotobuki Solution Co., Ltd., a company which locates its headquarters and branches in Japan (hereinafter referred to as the 'Company') with regard to the use of an application or applications or any related service for use on smartphones, gaming console systems or personal computer systems (hereinafter referred to as 'Content' as a whole), the website where the Company provides information regarding the Content (hereinafter referred to as the 'Company Website'), the email newsletter service (hereinafter referred to as 'Newsletter') made available by the Company, and with regard to the use (hereinafter any user referred to as 'Customer' as a whole) of a distribution or purchasing service operated by the Company or by a third party (hereinafter referred to as 'Distribution Service'), or correspondence of information or exchange of articles required to carry out business with both corporate or personal entities including but not limited to media, business partners or said candidates (hereinafter referred to as 'Business Correspondence') that uses information considered as personal information such as email address. The Kotobuki Privacy Policy is based on the fundamental policies set out by the Company regarding the protection of personal information (http://www.kemco-games.com/global/privacy.html, hereinafter referred to as the 'Basic Privacy Policy'). The Kotobuki Privacy Policy encompasses the Company's Basic Privacy Policy in its entirety.
The Kotobuki Privacy Policy is also intended as an explanation of functions enabling the Content to transmit data without interaction from the Customer. This explanation is hereinafter referred to as the 'Application Privacy Policy'. Furthermore, the Kotobuki Privacy Policy is intended as an explanation of the content of data transmitted when the Company Website or Distribution Service are used.

The Customer should be sure to read the Kotobuki Privacy Policy carefully and consent to it before using the Content, the Company Website or a Distribution Service operated by the Company.
Should the Customer desire to cancel the consent to the Kotobuki Privacy Policy during the use of the Content, the Customer shall uninstall the Content.

This Privacy Policy shall not apply to the following Content and separate privacy policies shall apply. In order to use the following Content, please refer to each privacy policy. However, each privacy policy is available only in Japanese.

【Content】

• Android apps provided via KEMCO Empire for Sugotoku:　EULA and Privacy Policy for Sugotoku established by NTT DOCOMO, INC. shall apply.

The Company is the controller and the processor within the meaning of the General Data Protection Regulation (Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 -"GDPR").

Personal computer systems, smartphones and other information terminals accumulate large amounts of data. Within this data there is data containing personal information, data containing no personal information, and data which does not in and of itself contain personal information, but which can be linked, by analysis or reference, to data which would enable personal identification. A characteristic of platforms for smartphones and other similar information terminals is the frequent transmission of data to outside locations. This data is used by a wide range of services.
The Company regards both the protection of personal information and the right to privacy as important, and as such, states that all data or information acquired by the Company from terminals shall be obtained and stored in an appropriate way, and that the involvement of the Customer in the provision of this data or information shall be suitable. The processes by which the Company obtains data or information shall be transparent in their entirety, data and information obtained shall be stored in a suitable and secure fashion, and the means by which the Customer is involved in the provision of data or information shall be appropriate. Further, in the event of an unforeseen problem, the Company shall act to deal with this problem in a swift and appropriate manner.
Furthermore, the Company states that the Content, the Company Website and any Distribution Service operated by the Company are designed and developed with regard for the protection of personal information and the right to privacy, so as to be fit and proper in these respects.

This Article sets out the fundamental policies of the Company regarding the protection of personal information.
The Company regards the appropriate handling and adequate protection of personal information as an important social responsibility.
Accordingly, the Company has established the following policies regarding the protection of personal information, and strives to raise awareness of these policies.

1. Clear definition of the purpose of usage, and restrictions governing usage
• The Company, in the collection, usage, and provision of personal information, shall, respecting the rights of individuals, make clear the reasons for the collection of any information, and the limits and restrictions governing the usage and provision of such information. Further, the Company shall collect, use and provide this information in an appropriate manner.
2. Management of personal information
• The Company shall keep any personal information in its possession strictly confidential. The Company shall appoint an information management supervisor for each department, and shall manage personal information so as to ensure that the information is not used in any way that may exceed the scope to which the individual has given consent, or that may exceed the scope defined by law or other ordinances. Should any personal information become unnecessary through the termination of the retention period defined by law or the like, or after the period required to provide the Service, the Company shall promptly discard or delete such personal information.
3. Security and accuracy
• The Company shall strive to create and raise awareness of the importance of data security. The Company shall ensure the security and accuracy of data, and shall make every effort to prevent unauthorized access to personal information, loss, destruction or falsification of data, and the leaking of personal information. Should any issue arise, the Company shall strive to minimize the damage and adopt corrective measures immediately.
4. Observance of and compliance with laws
• The Company shall observe and comply with laws governing the protection of personal information, including equivalent laws established by states or guidelines, etc., established by administrative bodies where our service is provided.
  The Company locates its headquarters and branches in Japan and provides various Content services , such as the distribution of games, across the world. In the case the user of related services is located in the European Economic Area (EEA: including 27 EU countries and also Iceland, Liechtenstein and Norway), the Company shall manage personal information in compliance with the EU General Data Protection Regulation (GDPR).
5. Continuous improvement of regulations regarding personal information
• The Company shall, by means of training, and by means of improvements to the auditing system, ensure that both officers and employees of the Company are fully aware of the importance of the protection of personal information. Further, the Company shall develop and implement regulations regarding the management of personal information, and shall review and improve these regulations on an ongoing basis.

This Article explains the data transmitted by the Content itself.

• A User Identification String (a special string of letters/numbers linked to the Customer's usage history for each service)
  This data will be transmitted to server which is managed by the Company and located in Japan.
  The Company is not able to identify any of the Customer's personal information from this data.
  This data will not be provided to any third party.
  The Content may access Cookies (see below) stored on the terminal, in order to obtain this data.
  
• A unique number for each terminal, or a unique number for each network subscriber
  This data will be transmitted to server which is managed by the Company and located in Japan.
  The Company is not able to identify any of the Customer's personal information from this data.
  This data will not be provided to any third party.
  

• Game data version information, used to determine whether or not it is necessary to update the game data.
  This data will be transmitted to server which is managed by the Company and located in Japan.
  The Company is not able to identify any of the Customer's personal information from this data.
  This data will not be provided to any third party.
  
• Data regarding the user name, User Identification String, and information about the characters in the game
  This data will be transmitted to server which is managed by the Company and located in Japan.
  The Company is not able to identify any of the Customer's personal information from this data.
  This data will not be provided to any third party.
  
• Safe Save Backup Data
  This data will be transmitted to server which is managed by the Company and located in Japan.
  This data is stored in connection with the previously mentioned KEMCO ID.
  The Company does not originally include any personal information in this data, however, in case the Customer intentionally includes any personal information in the game data in connection with the KEMCO ID or email address, these personal information may be stored concurrently.
  This data will not be provided to any third party.
  The Company may delete this data upon Customer request. In such case, please contact KEMCO user support from the lower part of this Kotobuki Privacy Policy.
  

• The name of the Content
• A unique name for the Content used by the system (a package name, etc.)
• The version name of the Content
• The verified status of the Content
• The name of the terminal on which the Content is being run, the base system name, and the base system version name
• The User Identification String
  This data will be transmitted to server which is managed by the Company and located in Japan.
  The Company is not able to identify any of the Customer's personal information from this data.
  However, because of the system by which email is transmitted, the email address of the Customer will be transmitted to the Company.
  If the Customer includes personal information in the email of his/her own accord, or if the email signature contains personal information such as a name or address, this information may be transmitted to the Company.
  Additionally, the Company may request personal information, such as a postal address, in order to provide further support, or to send a necessary item, etc.
  Personal information obtained by the Company for the purposes of user support is used only for support, and is not stored in any form linked to data transmitted automatically by the Content.
  

Middlewares are tool softwares used to design, create or execute the Content, and most of the Content are created using a middleware called Unity.
The provider of Unity, Unity Technologies, states that content using Unity may collect data. Unity Technologies also states that this data collection is to provide, administer, operate and improve their services required for the functionality of the Content. The Company shall consent to this statement and relevant data collection through part of our Content.
For more information about the data collected by Unity Technologies and how it is used, please consult the Unity Technologies' Privacy Policy. The followings are just an example of data collection.

• IDFV for iOS devices or terminal identifiers such as Android IDs for Android devices
  This data will be transmitted to Unity Technologies.
  The Company cannot access this data.
  It may lead to the identification of the personal information if combined with existent information.
• IP Address
  This data will be transmitted to Unity Technologies.
  The Company cannot access this data.
  It may lead to the identification of the personal information if combined with existent information.
• The ID of the Content
  This data will be transmitted to Unity Technologies.
  The Company cannot access this data.
  It may lead to the identification of the personal information if combined with existent information.

The Content may include one or more of the following external modules. These modules serve to enable certain functions, or to improve the substance of the Content.
In the case such modules are included, a prior consent confirmation screen is displayed in the Content. If the Customer shall not agree on this consent confirmation screen, the Content may not be used.
External modules are programs created and provided by third parties. These programs are incorporated into the Content in order to enable features including verification, the display of advertisements, or analysis of the frequency of use of the Content. These modules are independent of the functions of the Content itself.
External modules may collect data independently of the Content, and may transmit this data to a third party other than the Company.
This Article details the external modules which may be incorporated into the Content, details of the provider, and the provider's declared Privacy Policy. The data transmitted and data destination differ depending on the external module.
For detailed information, please refer to the explanations, regulations and Privacy Policy of each provider.

• Google Play License Verification Library(LVL)
  Module details (English): http://developer.android.com/google/play/licensing/adding-licensing.html
  Provided by: Google LLC
  Provider URL (English): http://www.google.com/
  Provider Privacy Policy (English): https://policies.google.com/privacy?hl=en

• Google Play In-App Billing API
  Module details (English): http://developer.android.com/google/play/billing/api.html
  Provided by: Google LLC
  Provider URL (English): http://www.google.com/
  Provider Privacy Policy (English): http://www.google.com/intl/en/policies/privacy/
• Amazon In-App Purchasing API
  Module details (English): https://developer.amazon.com/sdk/in-app-purchasing.html
  Provided by: Amazon.com, Inc.
  Provider URL (English): http://www.amazon.com/
  Provider Privacy Policy (English): http://www.amazon.com/gp/help/customer/display.html?nodeId=468496
  

• Google Analytics
  Module details (English): http://www.google.co.jp/intl/en/analytics/
  Provided by: Google LLC
  Provider URL (English): http://www.google.com/
  Provider Privacy Policy (English): http://www.google.com/intl/en/policies/privacy/
  ※ This module transmits data regarding application usage conditions to the module provider. The provider then provides usage statistics to the Company.
• Party Track
  Module details (English): Not made public
  Provided by: Adways Inc.
  Provider URL (English): https://partytrack.it/
  Provider Privacy Policy (English): http://www.adways.net/en/privacy.html
• Unity Analytics
  Module details: Not made public
  Provided by: Unity Technologies
  Provider URL (English): https://unity3d.com/
  Provider Privacy Policy (English): https://unity3d.com/legal/privacy-policy
  ※ This module transmits data regarding application usage conditions to the module provider. The provider then provides usage statistics to the Company.

• Google AdMob Ads
  Module details (English): https://developers.google.com/mobile-ads-sdk/docs/?hl=en
  Provided by: Google, Inc.
  Provider URL (English): http://www.google.com/
  Provider Privacy Policy (English): http://www.google.com/intl/en/policies/privacy/
  
  ※ In some cases, prior consent regarding this module may be reset from the in-app menu.
• Chartboost
  Module details (English): https://answers.chartboost.com/hc/en-us
  Provided by: Chartboost, Inc.
  Provider URL (English): https://www.chartboost.com/
  Provider Privacy Policy (English): https://help.chartboost.com/legal/privacy
• AdLantis
  Module details: Not made public
  Provided by: ValueCommerce Co., Ltd.
  Provider URL (Japanese): https://www.valuecommerce.co.jp/
  Provider Privacy Policy (English): https://www.valuecommerce.co.jp/en/privacy_policy/
• Google AdWords
  Module details: https://adwords.google.com
  Provided by: Google LLC
  Provider URL (English): http://www.google.com/
  Provider Privacy Policy (English): http://www.google.com/intl/en/policies/privacy/
• Tapjoy
  Tapjoy
  Module details (English): https://home.tapjoy.com/developers/resources/
  Provided by: Tapjoy, Inc.
  Provider URL (English): https://www.tapjoy.com/
  Provider Privacy Policy (English): https://dev.tapjoy.com/en/legal/Privacy-Policy
• adfurikun
  adfurikun
  Module details: Not made public
  Provided by: ADFULLY Inc.
  Provider URL (Japanese): https://adfurikun.jp/adfurikun/
  Provider Privacy Policy (Japanese): https://adfurikun.jp/adfurikun/cms/detail/code/9998
• nend
  Module details (Japanese): http://nend.net/privacy/sdkpolicy
  Provided by: FAN Communications, Inc.
  Provider URL (English): http://www.fancs.com/en/ , http://nend.net/
  Provider Privacy Policy (English): http://www.fancs.com/en/privacy
• AMoAd
  Module details: Not made public
  Provided by: CyberAgent, Inc.
  Provider URL (Japanese): http://www.amoad.com/
  Provider Privacy Policy (Japanese): https://privacy-policy.cyberagent.ai/
• AdColony
  Module details: Not made public
  Provided by: Opera Mediaworks
  Provider URL (English): http://operamediaworks.com/
  Provider Privacy Policy (English): http://operamediaworks.com/advertising-services-privacy-policy
• Vungle
  Module details: https://v.vungle.com/sdk
  Provided by: Vungle, Inc.
  Provider URL: http://vungle.co.jp/
  Provider Privacy Policy: http://vungle.com/privacy/
• UnityAds
  Module details: Not made public
  Provided by: Unity Technologies
  Provider URL(English): https://unity3d.com/
  Provider Privacy Policy(English): https://unity3d.com/legal/privacy-policy
• maio
  Module details: https://github.com/imobile-maio
  Provided by: i-mobile Co.,Ltd.
  Provider URL(Japanese): https://www.i-mobile.co.jp/index.html
  Provider Privacy Policy(Japanese): https://www.i-mobile.co.jp/privacy.html

• Facebook API
  Module details：https://developers.facebook.com/
  Provided by：Meta Platforms, Inc.
  Provider URL ：https://www.facebook.com/facebook
  Provider Privacy Policy：https://www.facebook.com/about/privacy/
• Twitter Platform
  Module details：https://dev.twitter.com/
  Provided by：X Corp.
  Provider URL ：https://about.twitter.com/company
  Provider Privacy Policy：https://twitter.com/privacy

• Fello
  Module details(Japanese)：https://fello.net/help/getstarted
  Provided by：GENIEE, Inc.
  Provider URL (English)：http://en.geniee.co.jp/
  Provider Privacy Policy (English)：http://en.geniee.co.jp/privacy/
• Google Cloud Messaging
  Module details (English): https://developers.google.com/cloud-messaging/
  Provided by: Google LLC
  Provider URL (English): http://www.google.com/
  Provider Privacy Policy (English): http://www.google.com/intl/en/policies/privacy/

• Google Play Games Services
  Module details(English): https://developers.google.com/games/services/
  Provided by: Google, Inc.
  Provider URL (English): http://www.google.com/
  Provider Privacy Policy (English): http://www.google.com/intl/en/policies/privacy/
• Firebase
  Module details(English): https://firebase.google.com/
  Provided by: Google, Inc.
  Provider URL (English): http://www.google.com/
  Provider Privacy Policy (English): http://www.google.com/intl/en/policies/privacy/

• Access Analysis Tool
  Any Distribution Service operated by the Company and the Company Website may use the following tools to analyze the access log and usage conditions:
  
  • Google Analytics
  ※ For details, see above.
  ※ This tool uses Cookies (see below).
  
• Cookies
  
  • About Cookies
  Cookies are data stored on the Customer's device when browsing websites, and are issued by the server of each website. They are used for either sending information from website (by the server) to device or returning information from device (by the browser) to website.
  Information contained in cookies can only be read and edited by their issuer.
  There are a variety of cookies but mostly they can be classified into two types depending on their term of validity.
  
  
  • Session Cookies: Temporary cookies that are deleted after leaving the website.
  • Persistent cookies: Longer-term cookies that are deleted after the expiration term specified by the issuer, or that will persist until the Customer deletes them.
  
  
  In case the use of the cookies is not allowed, there might be the possibility to be unable to use partly or whole function of the Distribution Service and the Company Website.
  
  
  • Why Cookies are necessary
  The Company uses cookies as essential technologies to provide distributional functions through the Distribution Service and Content.
  
  • KEMCO Empire
    https://android.kemco-mobile.com/app/index.php
  • KEMCO Space 200
    https://android.kemco-mobile.com/docomo_m/index.php
  • KEMCO Koryaku Hiroba
    https://q.kemco.jp/
  
  In the Distribution Service, cookies are used only for the purpose of enabling or promoting electronic communication necessary for the services and might record usage status essential for the functional realization of the service, track the Customer's ID to enable the browsing of usage history, or store the proper settings in the Customer's device.
  In HTML5 apps, cookies are used only for the purpose of recording Customer's login IDs essential for the functional realization of the service.
  Additionally, the Company may use third party modules (programs to add search, video, SNS functions to the website) to ensure the convenience and attractiveness of the website, which might issue own cookies individually for the purpose of realizing each service, improving functions through the analysis of usage status, or displaying advertisements that fits Customer's needs.
  
  
  
  • Details of cookies used / Cookies issued by the Company

  Cookies used in KEMCO Empire and KEMCO Space 200
  No.	Type	Name	Purpose	Valid Period
  1	Strictly Essential	kemcouserid	Records Customer-dependent random character string to distinguish the Customer and provide the service without the input of IDs.	2 years
  2	Strictly Essential	OPENID	Records the OpenID issued by NTT DOCOMO, INC. and implements secure and convenient services with the use of OpenID.	30 minutes
  3	Strictly Essential	ret	Records the necessary value to enable the website to behave regularly after the purchase of the Content.	24 hours
  4	Strictly Essential	SUID	Records the sp Mode ID issued by NTT DOCOMO, INC. and enables convenient Docomo validation or payment services.	2 years

  
  

  Cookies used in KEMCO Koryaku Hiroba
  No.	Type	Name	Purpose	Valid Period
  1	Strictly Essential	qa_key	Records Customer-dependent random character string to distinguish the Customer uniquely	48 hours

  
  
  • Details of cookies used / Cookies issued by third parties
  Sometimes cookies issued by third parties may be stored in the Customer's device during the use of the Distribution Service or Company Website.
  
  
  • Google LLC　(1600 Amphitheatre Parkway, Mountain View, CA 94043, USA. Cookie Policy)
  The Company uses video content on its Distribution Service and Company Website to ensure attractive Content experience. Video content are displayed using external modules of YouTube, a video-sharing service operated by Google LLC., and said modules might issue cookies for the purpose of maintenance of video view functions or analysis of usage status.
  
  
  • X Corp.　(1355 Market Street, Suite 900 San Francisco, CA 94103, USA. Cookie Policy)
  The Company uses social plugin functions provided by X Corp. on its Distribution Service and Company Website to ensure enough exposure and communication of the Content on SNS for SNS users. Said plugins might issue cookies for the purpose of maintenance of SNS functions or analysis of usage status.
  
  
  • Meta Platforms, Inc.　(1601 Willow Road ,Menlo Park, CA 94025 ,USA. Cookie Policy)
  The Company uses Facebook social plugin functions provided by Meta Platforms, Inc. on its Distribution Service and Company Website to ensure enough exposure and communication of the Content on SNS for SNS users. Said plugins might issue cookies for the purpose of providing, personalizing and improving their products.
  
  
  • LINE Corporation　(Yotsuya Tower 23rd FL., 1-6-1 Yotsuya, Shinjuku-ku, Tokyo, 160-0004, Japan. Cookie Policy)
  The Company uses LINE social plugin functions provided by LINE Corporation on its Distribution Service and Company Website to ensure enough exposure and communication of the Content on SNS for SNS users. Said plugins might issue cookies for the purpose of confirming the status of usage, as well as for the maintenance and improvement, security, and prevention of unauthorized or fraudulent use or abuse, of their services.
  
  
• Web Beacons
  Web Beacons are compact programs or special images embedded in websites or HTML emails. They are useful for analysis of how a website has been browsed, or an HTML email read, etc.
  Any Distribution Service operated by the Company and the Company Website may use Web Beacons. In cases where Web Beacons are used, the Web Beacons shall not transmit data such as the Customer's personal information without permission.

The following user information related to the Content or to the distribution service may be acquired separately by the Company, via a direct request to the User.

• Information for business correspondence
  The Company might obtain the following information through the exchange of business cards, oral or email communications and contact individuals using said information, however, said information will be used solely for the purpose of business correspondence, and will not be used for any other purposes.
  
  • The name of the individual
  • Account contact information of the individual
  • Email address
  • Facebook account
  • Twitter account
  • Chatwork account
  • Slack account
  • Skype account
  ※Including but not limited to any other electronic means to enable communications.
  
  • Phone number (fixed or mobile) of the individual
• Information for user support
  The Company might request to provide the following information, in order to resolve any functional issue or for the Customer interest (based on GDPR Art.6(1)(f))), via a user support request on public contacts such as email addresses and phone numbers disclosed on the Distribution Service by the Company or Company Website, which are not provided via the Content itself.
  
  • The name of the User
  • The contact information of the User such as email address or phone number
  • The name of the Content
  • The name of the terminal
  This information will be used solely for the purpose of user support, and will not be used for any other purposes. Once user support is terminated, this information will be deleted or stored in a secure format not to be used for other purposes.
  
• Information for visit or shipping
  The Company might request to provide the following in a case where such information is necessary.
  
  • The name of the User
  • The address and post(zip) code of the User
  • The contact information of the User such as email address or phone number
  This information will be used in the event should user support difficulties occur where the Company staffs need to visit or send any goods for compensation, or where the Company needs to send any rewards for the legitimate Customer interest (based on GDPR Art.6(1)(f))), and will not be used for any other purposes. Once the purpose is accomplished, this information will be deleted or stored in a secure format not to be used for other purposes.
  
• User Information for email newsletter service
  Email newsletter service delivers product information of the Company directly to the User via email, and is provided via the Company Website, the Distribution Service or the Content. In order to subscribe to the email newsletter, the User will send the following information via email or website to the server located in Japan that the Company manages.
  
  • The email address used to receive newsletters
  • The type of the newsletter service (for Android™ or for iOS)
  This information will be used only to send newsletters to and will be stored in a secure format not to be used for other purposes. Subscribers to the newsletter service can delete the registered information by unsubscribing via the steps indicated in the newsletter. In the event that a request to unsubscribe is provided via email, the stored email address will be manually deleted.
  
• User Information for KEMCO Koryaku Hiroba
  The KEMCO Koryaku Hiroba is a user-participatory communication space for the purpose of discussing and getting tips about the Company products. Posting comments on the KEMCO Koryaku Hiroba website does not require a user registration, however, in order to improve the usefulness and convenience of the service, it provides user registration and notification functions. When using these functions, the following information will be sent to our servers located in Japan.
  
  • E-mail address used as user ID
  • Password required for login
  • E-mail address used for notifications
  This information will be used only for the KEMCO Koryaku Hiroba and will be stored in a secure format not to be used for other purposes until the end of its termination of service. Requests for the deletion of posts, comments or user registrations can be sent to the Company's user support via email. The Company will manually delete said stored information upon request.
  
• Regarding the deletion of information
  In the case the information stated in this Article is stored within the Company, please contact the Company's user support with any inquiries regarding the verification or the deletion of said information.
  

Under GDPR, the Customer located in the EEA (data subjects) are entitled to exercise the following rights.

• Right of Access: Right to find out what kind of personal information is held about the Customer and get a copy of this information.
  


• Right of Rectification: Right to ask for Customer's information to be updated or corrected.


• Right to Data Portability: Right to receive a copy of the information the Customer (data subjects) has provided under contract so the Customer can provide it to another organization.


• Right to Restrict Use: Right to ask for personal information to stop being used in certain cases, including if the Customer believes that their personal information is incorrect or the use is unlawful.


• Right to Object: Right to object to use of information where a party is processing it on legitimate interest basis, and object to have personal information deleted.


• Right to Erasure: Right to request personal information to be deleted.

Representation for data subjects in the EU and the UK
We value your privacy and your rights as a data subject and have therefore appointed Prighter as our privacy representative and your point of contact.

Prighter gives you an easy way to exercise your privacy-related rights (e.g. requests to access or erase personal data). If you want to contact us via our representative Prighter or make use of your data subject rights, please visit: https://prighter.com/q/15235383332

• When the Content is updated to a new version, there may be changes to the user information transmitted, to the purpose, and to the destination to which the data is transmitted. In these cases there may also be changes or alterations made to the explanations regarding the transmission of data as detailed in the Kotobuki Privacy Policy. When updating the Content to a new version, please be sure to check the Kotobuki Privacy Policy. Please also be aware that the Company reserves the right, without informing the Customer beforehand, to update or revise the Kotobuki Privacy Policy, for example in the case of the enactment of a new law or a change to an existing law, etc.
  


• The Kotobuki Privacy Policy exists in a number of languages, for the convenience of non-Japanese-speaking Customers. The content and validity of each version is the same, but in the case of a discrepancy between versions of the Kotobuki Privacy Policy in different languages, the Japanese-language version shall be held to be correct.


• The Company shall declare that it shall not collect personal information without parental consent knowing the subject is under 16 (applying laws with more strict age restriction govern), and shall delete with proper measures such personal information collected from users with age restrictions in the case it becomes clear that the personal information have been collected without parental consent.


• Customer under the designated age restriction shall agree not to provide any personal information without parental consent.

【Kotobuki Solution Co., Ltd. Enquiries】
Please contact the Company at the following email address in the case of questions or enquiries regarding the handling of personal or user information by the Company.

• EMAIL：keitai-info@kemco.jp

Enquiries to the Company’s Data Protection Officer may be sent to the following email address.

• EMAIL：dpo@kemco.game

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Supplementary Provisions

[EULA] established on 2012.08.01
[EULA] revised on 2013.11.01
[Privacy Policy] established on 2013.11.01
[Privacy Policy] revised on 2013.12.18
[Privacy Policy] revised on 2014.01.23
[Privacy Policy] revised on 2014.10.24
[EULA] revised on 2015.02.28
[Privacy Policy] revised on 2015.11.26
EULA and Privacy Policy is merged to one page on 2016.05.26
revised on 2016.05.26
revised on 2016.08.18
revised on 2016.10.24
revised on 2017.03.15
revised on 2017.06.27
revised on 2017.11.08
revised on 2018.02.28
revised on 2018.05.24
revised on 2018.09.26
revised on 2019.08.07
revised on 2020.07.14
revised on 2021.03.17
revised on 2021.06.10
revised on 2021.07.07
revised on 2023.05.11


IOS is a trademark or registered trademark of Cisco in the U.S. and other countries and is used under license.
Android is a trademark of Google LLC
All other company names, product names and service names shown in this agreement are trademarks, registered trademarks or property of their respective owners.