gumi Inc. Privacy Notice for California Residents
Effective Date: September 29, 2020
This Privacy Notice for California Residents supplements the information contained in gumi Inc.'s(“gumi”, “we”, “us” or “our”) general Privacy Policy (https://gu3.co.jp/en/policy/) and applies solely to
all customers, prospective customers, visitors, users, players, and others who reside in the State ofCalifornia ("users" or "you"). We adopt this notice to comply with the California Consumer Privacy Act
of 2018 (CCPA) and any terms defined in the CCPA have the same meaning when used in this Notice.
Information We Collect
We collect information that identifies, relates to, describes, references, is reasonably capable of being
associated with, or could reasonably be linked, directly or indirectly, with a particular user, consumer,
household, or device ("personal information"). Personal information does not include:•

Publicly available information from government records.

•

Anonymous or de-identified, consumer information.

•

Aggregated consumer information.

In particular, we have collected the following categories of personal information from users within thelast twelve (12) months:

Category

Collected

A. Identifiers.

YES

B. Personal information categories listed in the California Customer Records statute (Cal.
Civ. Code § 1798.80(e)).

YES

C. Protected classification characteristics under California or federal law.

YES

D. Commercial information.

YES

E. Biometric information.

NO

F. Internet or other similar network activity.

YES

G. Geolocation data.

YES

H. Sensory data.

NO

I. Professional or employment-related information.

YES

J. Non-public education information (per the Family Educational Rights and Privacy Act(20 U.S.C. Section 1232g, 34 C.F.R. Part 99)).

NO

K. Inferences drawn from other personal information.

NO

We obtain the categories of personal information listed above from the following categories of sources:
Category
Category A: Identifiers.

Sources
Users of our website, applications and services, users’
devices, data services, social network services, and service
providersCategory B: California Customer
Records personal information
categories.

Users of our website, applications and services, users’
devices, data services, service providers, and social network
services

Category C: Protected classification
characteristics under California orfederal law.

Users of our website, applications and services, users’
devices, data services, service providers, and social network
services

Category D: Commercial information.

Users of our website, applications and services, users’
devices, data services, service providers, and social network
services

Category E: Biometric information.

NA

Category F: Internet or other similar
network activity.

Users of our website, applications and services, users’
devices, data services, service providers, and analytic
services

Category G: Geolocation data.

Internet Protocol address, device shared location, and wi-fi
connection location.

Category H: Sensory data.

NA

Category I: Professional or
employment-related information.

Users of career and job opening pages of our website.

Category J: Non-public education
information.

NA

Category K: Inferences drawn fromother personal information.

Users of our website, applications and services, users’
devices, data services, service providers, social network
services, and analytic services

Use of Personal Information
We may use, or disclose the personal information we collect for one or more of the following purposes:
Category

PurposesCategory A: Identifiers.

To provide, support, personalize, and develop and operate our website,
applications and services; to create, maintain, customize, and secure youraccount with us; to process your requests, purchases, transactions, andpayments and prevent transactional fraud; to provide you with support andto respond to your inquiries, including to investigate and address yourconcerns and monitor and improve our responses; to update, debug
content, mechanics and functionality in our applications and services, tofacilitate user’s community and social interactions, user acquisition andadvertising; to help maintain the safety, security, and integrity of our
website, applications and services, databases and other technology assets,
and business; for testing, research, analysis, and development, including todevelop and improve our website, applications, and services; to respond tolaw enforcement requests and as required by applicable law, court order,2

or governmental regulations; and as described to you when collecting yourpersonal information or as otherwise set forth in the CCPA.
Category B: California
Customer Records
personal information
categories.

To provide, support, personalize, and develop and operate our website,
applications, and services; to create, maintain, customize, and secure youraccount with us; to process your requests, purchases, transactions, andpayments and prevent transactional fraud; to provide you with support andto respond to your inquiries, including to investigate and address yourconcerns and monitor and improve our responses; to update, debug
content, mechanics and functionality in our applications and services, tofacilitate user’s community and social interactions, user acquisition andadvertising; to help maintain the safety, security, and integrity of our
website, applications and services, databases and other technology assets,
and business; for testing, research, analysis, and development, including todevelop and improve our website, applications, and services; to respond tolaw enforcement requests and as required by applicable law, court order,or governmental regulations; and as described to you when collecting yourpersonal information or as otherwise set forth in the CCPA.

Category C: Protectedclassification
characteristics under
California or federal law.

To provide, support, personalize, and develop and operate our website,
applications, and services; to create, maintain, customize, and secure youraccount with us; to process your requests, purchases, transactions, andpayments and prevent transactional fraud; to provide you with support andto respond to your inquiries, including to investigate and address yourconcerns and monitor and improve our responses; to update, debug
content, mechanics and functionality in our applications and services, tofacilitate application player’s community and social interactions, user
acquisition and advertising; to help maintain the safety, security, andintegrity of our website, applications and services, databases and othertechnology assets, and business; for testing, research, analysis, anddevelopment, including to develop and improve our website, applications
and services; to respond to law enforcement requests and as required byapplicable law, court order, or governmental regulations; and as describedto you when collecting your personal information or as otherwise set forthin the CCPA.

Category D: Commercial
information.

To provide, support, personalize, and develop and operate our website,
applications, and services; to create, maintain, customize, and secure youraccount with us; to process your requests, purchases, transactions, andpayments and prevent transactional fraud; to provide you with support andto respond to your inquiries, including to investigate and address yourconcerns and monitor and improve our responses; to update, debug
content, mechanics and functionality in our applications and services, tofacilitate application player’s community and social interactions, user
acquisition and advertising; to help maintain the safety, security, andintegrity of our website, applications and services, databases and othertechnology assets, and business; for testing, research, analysis, anddevelopment, including to develop and improve our website, applications
and services; internal research; to evaluate or conduct a merger,
divestiture, restructuring, reorganization, dissolution, or other sale ortransfer of some or all of our assets, whether as a going concern or as partof bankruptcy, liquidation, or similar proceeding, in which personal3

information held by us about our website, application and service users isamong the assets transferred; to respond to law enforcement requests andas required by applicable law, court order, or governmental regulations;and as described to you when collecting your personal information or asotherwise set forth in the CCPA.
Category E: Biometric
information.

NA

Category F: Internet orother similar network
activity.

To provide, support, personalize, and develop and operate our website,
applications, and services; to create, maintain, customize, and secure youraccount with us; to process your requests, purchases, transactions, andpayments and prevent transactional fraud; to provide you with support andto respond to your inquiries, including to investigate and address yourconcerns and monitor and improve our responses; to update, debug
content, mechanics and functionality in our applications and services, tofacilitate application user’s community and social interactions, user
acquisition and advertising; to help maintain the safety, security, andintegrity of our website, applications and services, databases and othertechnology assets, and business; for testing, research, analysis, anddevelopment, including to develop and improve our website and services;to evaluate or conduct a merger, divestiture, restructuring, reorganization,
dissolution, or other sale or transfer of some or all of our assets andintellectual property, whether as a going concern or as part of bankruptcy,
liquidation, or similar proceeding, in which personal information held by
us about our website, applications and services users is among the assets
transferred; to respond to law enforcement requests and as required byapplicable law, court order, or governmental regulations; and as describedto you when collecting your personal information or as otherwise set forthin the CCPA.

Category G: Geolocationdata.

To provide, support, personalize, and develop and operate our website,
applications, and services; to create, maintain, customize, and secure youraccount with us; to process your requests, purchases, transactions, andpayments and prevent transactional fraud; to provide you with support andto respond to your inquiries, including to investigate and address yourconcerns and monitor and improve our responses; to update, debug
content, mechanics and functionality in our applications and services, tofacilitate application user’s community and social interactions, user
acquisition and advertising; to help maintain the safety, security, andintegrity of our website, applications and services, databases and othertechnology assets, and business; for testing, research, analysis, anddevelopment, including to develop and improve our website, applications
and services; to evaluate or conduct a merger, divestiture, restructuring,
reorganization, dissolution, or other sale or transfer of some or all of ourassets and intellectual property, whether as a going concern or as part ofbankruptcy, liquidation, or similar proceeding, in which personal
information held by us about our website, application and service users isamong the assets transferred; to respond to law enforcement requests andas required by applicable law, court order, or governmental regulations;and as described to you when collecting your personal information or asotherwise set forth in the CCPA.

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Category H: Sensory
data.

NA

Category I: Professionalor employment-related
information.

To evaluate applications for employment made through our career and job
opening pages of our website.

Category J: Non-public
education information.

NA

Category K: Inferences
drawn from otherpersonal information.

To provide, support, personalize, and develop and operate our website,
applications and services; to create, maintain, customize, and secure youraccount with us; to process your requests, purchases, transactions, andpayments and prevent transactional fraud; to provide you with support andto respond to your inquiries, including to investigate and address yourconcerns and monitor and improve our responses; to update, debug
content, mechanics and functionality in our applications and services, tofacilitate application player’s community and social interactions, user
acquisition and advertising; to help maintain the safety, security, andintegrity of our website, applications, and services, databases and othertechnology assets, and business; for testing, research, analysis, andapplication development, including to develop and improve our website
and services; to evaluate or conduct a merger, divestiture, restructuring,
reorganization, dissolution, or other sale or transfer of some or all of ourassets and intellectual property, whether as a going concern or as part ofbankruptcy, liquidation, or similar proceeding, in which personal
information held by us about our website, application and service users isamong the assets transferred; to respond to law enforcement requests andas required by applicable law, court order, or governmental regulations;and as described to you when collecting your personal information or asotherwise set forth in the CCPA.

We will not collect additional categories of personal information or use the personal information wecollected for materially different, unrelated, or incompatible purposes without providing you notice.
Sharing Personal Information
We may disclose your personal information to a third party for a business purpose. When we disclose
personal information for a business purpose, we enter a contract that describes the purpose and requires
the recipient to both keep that personal information confidential and not use it for any purpose except
performing the contract.
We share your personal information with the following categories of third parties:
Disclosures of Personal Information for a Business Purpose
In the preceding twelve (12) months, gumi had disclosed the following categories of personal information
for a business purpose:

Disclosure for Business
PurposeCategory5Category A: Identifiers.

YES

Category B: California Customer Records personal information
categories.

YES

Category C: Protected classification characteristics under California orfederal law.

YES

Category D: Commercial information.

YES

Category E: Biometric information.

NA

Category F: Internet or other similar network activity.

YES

Category G: Geolocation data.

YES

Category H: Sensory data.

NA

Category I: Professional or employment-related information.

NO

Category J: Non-public education information.

NA

Category K: Inferences drawn from other personal information.

YES

We disclose your personal information for a business purpose to the following categories of third parties:•

Service providers.

•Customer Service Vendors;•

Computer Cloud Storage Providers;•

Payment and Auditing Processors;•

Quality Assurance Vendors;•Social Media Services, Advertising and Marketing Partners;•

Security Vendors and other Service Providers;•

Subsidiaries, Parent Companies, Joint Ventures and other Corporate Entities under Common
Ownership; and•Government entities, including law enforcement.

No Sales of Personal Information
In the preceding twelve (12) months, gumi had not sold personal information.

Your Rights and Choices
The CCPA provides consumers (California residents) with specific rights regarding their personal
information. This section describes your CCPA rights and explains how to exercise those rights.
Access to Specific Information and Data Portability Rights

6You have the right to request that we disclose certain information to you about our collection and use ofyour personal information over the past 12 months. Once we receive and confirm your verifiableconsumer request (see Exercising Access, Data Portability, and Deletion Rights), we will disclose to you:•

The categories of personal information we collected about you.

•

The categories of sources for the personal information we collected about you.

•

Our business or commercial purpose for collecting that personal information.

•

The categories of third parties with whom we share that personal information.

•

The specific pieces of personal information we collected about you (also called a data portability
request).

•If we disclosed your personal information for a business purpose, a separate list disclosing:•disclosures for a business purpose, identifying the personal information categories that eachcategory of recipient obtained.

Deletion Request Rights
You have the right to request that we delete any of your personal information that we collected from you
and retained, subject to certain exceptions. Once we receive and confirm your verifiable consumer request(see Exercising Access, Data Portability, and Deletion Rights), we will delete (and direct our service
providers to delete) your personal information from our records, unless an exception applies.
We may deny your deletion request if retaining the information is necessary for us or our service
provider(s) to:1.

Complete the transaction for which we collected the personal information, provide a service thatyou requested, take actions reasonably anticipated within the context of our ongoing business
relationship with you, or otherwise perform our contract with you.

2.

Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or
prosecute those responsible for such activities.

3.

Debug applications to identify and repair errors that impair existing intended functionality ofservices.

4.

Exercise free speech, ensure the right of another consumer to exercise their free speech rights, or
exercise another right provided for by law.

5.

Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 et.
seq.).

6.

Enable solely internal uses that are reasonably aligned with consumer expectations based on yourrelationship with us.

7.

Comply with a legal obligation.

8.

Make other internal and lawful uses of that information that are compatible with the context inwhich you provided it.

Exercising Access, Data Portability, and Deletion Rights
To exercise the access, data portability, and deletion rights described above, please submit a verifiableconsumer request to us by either:•

Emailing us at privacy@gu3.co.jp.

7•

Visiting us at https://gu3.co.jp/.

•

Write us at gumi Inc. Attn: Legal Department Sumitomo Fudosan Nishi-Shinjuku Building No. 5,
3F Nishi-Shinjuku 4-34-7 Shinjuku, Tokyo 160-0023 Japan.

Only you, or someone legally authorized to act on your behalf, may make a verifiable consumer request
related to your personal information. You may also make a verifiable consumer request on behalf of yourminor child.
You may only make a verifiable consumer request for access or data portability twice within a 12-month
period. The verifiable consumer request must:•

Provide sufficient information that allows us to reasonably verify you are the person about whom
we collected personal information or an authorized representative, which may include:••

game ID (a unique number that our applications and services applies to each user or player).

Describe your request with sufficient detail that allows us to properly understand, evaluate, andrespond to it.

In addition, if you do not have an account and you ask us to provide you with specific pieces of personal
information, we reserve the option to require you to sign a declaration under penalty of perjury that you
are the consumer whose personal information is the subject of the request.
We cannot respond to your request or provide you with personal information if we cannot verify youridentity or authority to make the request and confirm the personal information relates to you.
Making a verifiable consumer request does not require you to create an account with us.
We will only use personal information provided in a verifiable consumer request to verify the requestor's
identity or authority to make the request.
Response Timing and Format
We endeavor to respond to a verifiable consumer request within forty-five (45) days of its receipt. If werequire more time (up to 90 days), we will inform you of the reason and extension period in writing
including by email.
If you have an account with us, we will deliver our written response to that account. If you do not have an
account with us, we will deliver our written response by mail or electronically, at your option.
Any disclosures we provide will only cover the 12-month period preceding the verifiable consumer
request's receipt. The response we provide will also explain the reasons we cannot comply with a request,
if applicable. For data portability requests, we will select a format to provide your personal informationthat is readily useable and should allow you to transmit the information from one entity to another entity
without hindrance.
We do not charge a fee to process or respond to your verifiable consumer request unless it is excessive,
repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why
we made that decision and provide you with a cost estimate before completing your request.
Personal Information of Minors under Age 16
We do not sell the personal information of consumers we actually know are less than 16 years of age.

Non-Discrimination

8

We will not discriminate against you for exercising any of your CCPA rights. Unless permitted by the
CCPA, we will not:•Deny you our applications and services.

•

Charge you different prices or rates for our applications and services, including through granting
discounts or other benefits, or imposing penalties.

•

Provide you a different level or quality of our applications or services.

•

Suggest that you may receive a different price or rate for our applications or services or adifferent level or quality of our applications or services.

Other California Privacy Rights
California's "Shine the Light" law (Civil Code Section § 1798.83) permits users of our Website that are
California residents to request certain information regarding our disclosure of personal information tothird parties for their direct marketing purposes. To make such a request, please send an email toprivacy@gu3.co.jp or write us at: gumi Inc. Attn: Legal Department Sumitomo Fudosan Nishi-Shinjuku
Building No. 5, 3F Nishi-Shinjuku 4-34-7 Shinjuku, Tokyo 160-0023 Japan.
Changes to Our Privacy Notice
We reserve the right to amend this privacy notice at our discretion and at any time. When we makechanges to this privacy notice, we will post the updated notice on the Website and update the notice's
effective date. Your continued use of our Website following the posting of changes constitutes youracceptance of such changes.
Contact Information
If you have any questions or comments about this notice, the ways in which gumi Inc. collects and uses
your information described here and in the Privacy Policy, your choices and rights regarding such use, orwish to exercise your rights under California law, please do not hesitate to contact us at:
Website: https://gu3.co.jp/
Email: privacy@gu3.co.jp
Postal Address: gumi Inc. Attn: Legal Department Sumitomo Fudosan Nishi-Shinjuku Building
No. 5, 3F Nishi-Shinjuku 4-34-7 Shinjuku, Tokyo 160-0023 Japan

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