Privacy Policy
KOEI TECMO GAMES CO., LTD., with its principal place of business at KT Building, 4-3-6,Minatomirai, Nishi-ku, Yokohama, Kanagawa, 220-8503, Japan and having Mr. Hisashi Koinuma as
President and COO (hereinafter referred to as “Koei Tecmo”, “we”, “our”, or “us”), recognizes theimportance of personal information and promises to comply with the Act on the Protection of Personal
Information of Japan (the “APPI”) and other related laws and regulations and to handle your personal
information in a transparent, fair and secure manner.
1. Subject matter
This privacy policy stipulates that Koei Tecmo is a personal information handling business operator
under the APPI and that we are responsible for the acquisition and use of personal information inconnection with our provision of services and operation of other businesses.
2. Information to be acquired
We may acquire, use, and analyze the following kinds of information for the purposes specified in“3. Purposes of use of personal information.”(1) Identification information (user ID, user name, etc.)(2) Preference information (language and other preference information)(3) Online activity logs (logs of your activity within our services, including date and time, activity
type, IP address, cookies, device identifier, OS type and version, and purchase records)(4) Inquiry information (identification information, such as name, address, and e-mail address, ofyou or each of our business partners; services you use or are interested in; your computing
environment (platform, device model, OS type and version); and your messages and questions)(5) Location information(6) Information on employees and dispatched staff (name, address, and other information)(7) Information on applicants for recruitment (name, address, and other information)
If you do not provide personal information, all or some of our services may not be made available
to you. In addition, we may not be able to respond to your inquiries based on appropriate and correct
information.
3. Purpose of use of personal information
We use personal information to the extent necessary to achieve the purposes set out below.
(1)

To continue to provide products and services through the ascertainment of identification
information, etc.
1(2)To maintain and improve the quality of products and services through analysis of activity logs,etc.

(3)

To conduct prompt recovery from all problems in products and services through analysis ofactivity logs, etc.

(4)

To provide appropriate and correct information in response to your inquiries about products
and services through the use of inquiry information, etc.

(5)

To perform service termination procedures through the use of inquiry information, etc.

(6)

To develop new products and services through the analysis of inquiry information, etc.

(7)

To display ads personalized for you in our services through the analysis of activity logs, etc.

(8)

To conduct campaigns, etc. through the use of inquiry information, etc.

(9)

To send you products, prizes, and the like through the use of inquiry information, etc.

(10) To make personnel evaluations, personnel decisions (e.g., promotion, assignment, etc.), andto perform personnel management through the use of information on employees anddispatched staff(11) To notify or communicate with business partners for performance of operations through theuse of inquiry information(12) To decide whether to employ applicants or to select subcontractors through the use ofinformation on applicants for recruitment(13) To send you notices about our products or services through the use of inquiry information(14) To properly and efficiently perform operations other than those described in the foregoingitems
In order to achieve the above-mentioned purposes of use, we may, with your consent, provide a
third party with your personal data. When providing personal data to a third party, we are obligatedto supervise that third party to ensure proper management of your personal information
Other than the foregoing, we will not provide any personal data to any third party without your priorconsent, unless we are required to do so by laws and regulations, etc.
4. Joint use of personal data
We will, in the manner set out below, conduct joint use of the personal information we have acquired.
(1) Items of personal data subject to joint use
The acquired information set out below that falls under the category of personal data(i)

Identification information (user ID, user name, etc.)(ii)

Preference information (language and other preference information)(iii) Online activity logs (logs of your activity within our services, including date and time,2activity type, IP address, cookies, device identifier, OS type and version, and purchaserecords)(iv) Inquiry information (identification information, such as name, address, and e-mail address,of you or each of our business partners; services you use or are interested in; yourcomputing environment (platform, device model, OS type and version); and your messagesand questions)(v)

Location information(vi) Information on employees and dispatched staff (name, address, etc.)(vii) Information on applicants for recruitment (name, address, etc.)(2) Scope of joint users
Koei Tecmo’s group companies listed on the following webpage
https://www.koeitecmo.co.jp/e/company/group/(3) Purpose of use by joint users(i)

To continue to provide products and services through the ascertainment of identifying
information, etc.

(ii) To maintain and improve the quality of products and services through analysis of activitylogs, etc.
(iii) To conduct prompt recovery from all problems in products and services through analysisof activity logs, etc.
(iv) To provide appropriate and correct information in response to your inquiries about
products and services through the use of inquiry information, etc.
(v) To perform service termination procedures through the use of inquiry information, etc.
(vi) To develop new products and services through the analysis of inquiry information, etc.
(vii) To send you products, prizes, and the like through the use of inquiry information, etc.
(viii) To make personnel evaluations, personnel decisions (e.g., promotion, assignment, etc.),
and to perform personnel management through the use of information on employees(ix) To notify or communicate with business partners for performance of operations throughthe use of inquiry information(x) To decide whether to employ applicants or to select subcontractors through the use of
information on applicants for recruitment(xi) To properly and efficiently perform operations other than those described in the foregoing
items(4) Person responsible for management of personal data3

Hisashi Koinuma, President and COO
KOEI TECMO GAMES CO., LTD.
KT Building, 4-3-6, Minatomirai, Nishi-ku, Yokohama, Kanagawa, 220-8503, Japan
5. Measures taken for security control of retained personal data
We have analyzed various possible risks that may arise out of handling information and haveintroduced appropriate security control measures set out below to protect personal data from loss,
unauthorized access, falsification, leaks, etc.
(1) Establishment of a basic policy
We have established this privacy policy stipulating how to handle personal data and othermatters to ensure the proper handling of personal data.
(2) Formulation of internal rules regarding handling of personal data
We have established internal rules called “Rules for Safety Management of Personal Data” that
determine the reporting and communication system, measures for responding to information
leaks and other issues, and personal data management procedures and the like.
(3) Organizational security control measures
We have appointed a person in charge of handling personal data in each department that
handles personal data. In addition, we have specified the employees who handle personal data
and the scope of personal data handled by those employees, and we have also established areporting and communication system through which the person in charge will be notified if
there is any actual or possible violation of laws and regulations or our internal rules.
(4) Personnel security control measures
We regularly make announcements to our employees to raise their awareness regarding thehandling of personal data. Each of our employees is also required to submit a written pledge
to reduce the risk of information leaks when working at home.
(5) Physical security control measures
In the areas where personal data is handled, we control our employees’ entry into and exit fromthe areas, impose restrictions on devices, etc. to be brought into the area, and take measures toprevent unauthorized persons from seeing personal data.
(6) Technical security control measures
We have implemented access controls to limit the scope of persons in charge and the personal
information databases handled by those persons in charge.
(7) Understanding of the external environment
We implement security control measures after understanding local personal information
protection systems in each country where our group companies that store personal data arelocated.
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6. Request for notification of specific purposes of use of retained personal data
An individual who is identified and specified by personal information retained by us (hereinafterreferred to as an “Individual”) is entitled to request us to provide the specific purposes of use of that
Individual’s personal data retained by us. Even if such a request is made by an Individual, we may
refuse that request if any of the following applies:(1) if the purposes of use of such personal data are obvious because we have made the purposes
of use available to the Individual through this privacy policy or any other means;(2) if the notification or public announcement of the purposes of use is likely to harm theIndividual’s or a third party’s life, body, property, or any other right or interest;(3) if the notification or public announcement of the purposes of use is likely to harm any of ourrights or interests; or(4) if any competent governmental authority or the like requires our assistance in performance of
its legal duties under laws and regulations, and our notification to the Individual or publicannouncement of the purposes of use of the retained personal data received from that authority
or the like may hinder the performance of duties by that authority or the like.
In the case that an Individual makes such a request, if we decide not to notify the Individual of thepurposes of use of the retained personal data, then we will notify the Individual of that decision
without delay.
7. Request for disclosure of personal data, etc.
An Individual is entitled to request us to disclose the Individual’s personal data retained by us orrecords of provision and receipt of the Individual’s personal data retained by us to and from a thirdparty (hereinafter referred to as “Third Party Provision Records”). Even if such a request is madeby an Individual, we may refuse to disclose all or part of that personal data or Third Party Provision
Records if that disclosure falls under any of the following:(1) if that disclosure is likely to harm the Individual’s or a third party’s life, body, property, or any
other right or interest;(2) if that disclosure is likely to significantly hinder the proper performance of our business; or(3) if that disclosure causes a violation of any other law or regulation.
In the case that any Individual makes such a request, if we decide not to disclose all or a part of thepersonal data or Third Party Provision Records in question, if neither the personal data nor Third
Party Provision Records in question exist, or if it is difficult to make disclosure by the method
requested by the Individual, then we will notify the Individual to that effect without delay.
5Please note that a fee of 1,000 yen (including consumption tax) will be charged upon a request fordisclosure under this section.
8. Request for correction, etc. of personal data
An Individual is entitled to request us to make a correction, addition, or deletion (hereinafter referred
to as “Correction, Etc.”) in relation to the Individual’s personal data retained by us. If we determinethat it is necessary to act on such a request after our investigation of that request, we will make therequested Correction, Etc. of the personal data and notify the Individual to that effect without delay.
In addition, if we decide not to make the requested Correction, Etc., we will notify the Individual tothat effect without delay.
9. Request for cease using personal data, etc.
An Individual is entitled to make a request to us for the discontinuance of use or erasure (hereinafterreferred to as “Discontinuance of Use, Etc.”) of the Individual’s personal data retained by us. If wedetermine that such a request is reasonable, we will conduct Discontinuance of Use, Etc. of the
Individual’s personal data without delay to the extent required by laws and regulations and will
notify the Individual to that effect without delay. In addition, if we decide not to conduct
Discontinuance of Use, Etc., we will notify the Individual of that decision without delay.
In addition, the Individual is entitled to request us to cease providing personal data to a third party
if the Individual’s personal data retained by us is illegally provided to a third party. If we determinethat such a request is reasonable, we will cease providing personal data to a third party without delay
to the extent required by laws and regulations and will notify the Individual to that effect without
delay. In addition, if we decide not to cease providing personal data to a third party, we will notify
the Individual of that decision without delay.
10. Contact information for requests for disclosure of personal data, etc.
With regard to requests for notification of the specific purposes of use of retained personal data,
requests for disclosure, correction, addition, or discontinuance of use of personal data, requests for
cessation of provision to a third party or deletion of personal data, requests for disclosure of Third
Party Provision Records, or complaints and other inquiries concerning handling of personal data,
please contact us via e-mail at the information desk stated below.
Please note that the exercise of any of the rights described above may limit your use of all or a partof the games made available to you by us.

6Personal Information Protection Desk
KOEI TECMO GAMES CO., LTD
1-18-12, Minowa-cho, Kouhoku-ku, Yokohama, Kanagawa, 223-8503, Japan
E-mail: privacy@koeitecmo.co.jp
11. Provision of personal data to third parties residing in foreign countries
We may, with the consent of the Individual in question, provide information acquired for any of thepurposes of use set out in Section 3 to an entity residing in a foreign country.
In addition, for the purposes of use set out in Section 3, we may provide personal data retained byus to our overseas group companies. In this case, we will take necessary measures to ensure thecontinuous implementation of the equivalent measures (i.e., equivalent to the obligations imposedon personal information handling business operators under the APPI) by the recipients and will also,
upon the request of an Individual, provide information about those necessary measures.
Enforced from April 1, 2022

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