Privacy Policy

Welcome to Geisha Tokyo, Inc., an entertainment company offering apps for mobile devices.
We provide you with this Privacy Policy to describe how we manage information about users of our services.

1. Scope of this policy
The scope of this policy is limited to information and data collected or received by us through your use of our services. We are not responsible for the actions of individuals or companies with no relationship to us or our third-party partners, the content of their sites, the use of information or data you provide to them, or any products or services they may offer.

Any link to those sites does not constitute our sponsorship of, or affiliation with, those individuals or companies.

And, for users in EER and Switzerland, we have some specific provisions to respect the General Data Protection Regulation (GDPR) and the equivalent laws.

2. What information we ask you to provide
We will collect and process the following information during your use our services.
- Data about your device type and model, operating system version and platform.
- Your general location, such as region, country code, state, city, etc.
- Ad IDs (IDFA for iOS devices / AAID for Android devices) or the equivalents.
- Data about your activities on our apps, such as the app version, your game score, progress, time spent to use the app, purchase information, etc.
- Your basic Facebook profile information depending on your Facebook privacy settings.
- Your name and email address when you contact our customer support.

If you are under GDPR or the equivalent laws, we request your consent to allow us to manage the information above when you get started to use our apps.
If you do not agree with the request, you may not be able to use our apps.

3. Legal basis for use of your information
We consider that the legal bases for using your information as set out in this privacy policy are as follows:
(a) our use of your information is necessary to perform our obligations under any contract with you (for example, to comply with the terms of service of our apps); or
(b) you have provided us with your consent to do so. This applies in relation to the advertising and marketing materials delivered via our apps that are tailored to you and your preferences. You can control and withdraw your consent at any time.
(c) where (a) or (b) does not apply, our use of your information is necessary for our legitimate interests or the legitimate interests of others. Our legitimate interests are to:
  (i) run, grow and develop our business (as well as the businesses of our group companies) including funding our business by use of advertising revenues;
  (ii) operate, maintain and improve our apps and our marketing optimisation efforts;
  (iii) understand the way in which our apps are used; and
  (iv) for internal group administrative purposes.

If we rely on our (or another person's) legitimate interests for using your information, we will undertake a balancing test to ensure that our (or the other person's) legitimate interests are not outweighed by your interests or fundamental rights and freedoms which require protection of the personal information. You can ask us for information on this balancing test by using the contact details at the “Contact” section.

4. How we use your information
We will transfer, store and use the information listed above for the following purposes.
- To provide you with our apps and to create your account with the information.
- To improve our existing services and to develop new services with analysis and research about your activities on apps.
- To maintain our services secure and stable with monitoring suspicious or unexpected use.
- To understand you and your preferences and to propose ads more suitable to them.
- To send you notifications including confirmations, invoices, updates, security alerts, and support and administrative messages.
- To communicate with you about promotions, events and other news of services offered by us or our partners.
- To provide you with high-quality communication for customer support.


5. Sharing your information with others
We may share the information above with third-party partners or public authorities in your country of residence for the aforementioned purposes.
We are listing URLs of the partners’ privacy policies here.
5.1. With third-party analytics partners
To improve user experience, we would like to analyze mass information. We ask the following partners to collect, store, analyze and report us the data efficiently. For that, they can duplicate the information you provided us.

- Google: https://policies.google.com/privacy
- Facebook: https://www.facebook.com/privacy/explanation
- Tenjin: https://www.tenjin.io/privacy
- Unity: https://unity3d.com/legal/privacy-policy

5.2. With third-party advertising partners
We would like to serve you with great ads experiences on our apps. To achieve that, we cooperate with advertising partners to make the ads matched with you and your preferences. We may share your information with following providers.

- Google: https://policies.google.com/privacy
- Facebook: https://www.facebook.com/privacy/explanation
- AppLovin: https://www.applovin.com/privacy
- MoPub: https://www.mopub.com/legal/privacy
- ironSource: https://developers.ironsrc.com/ironsource-mobile/air/ironsource-mobile-privacy-policy
- TapJoy: https://www.tapjoy.com/legal/#privacy-policy
- Vungle: https://vungle.com/privacy/
- AdColony: https://www.adcolony.com/privacy-policy/
- ByteDance
- Unity: https://unity3d.com/legal/privacy-policy


5.3. With public authorities in your country
In accordance with relevant laws, we may have to disclose your information to public authorities in your country, whenever such disclosure is deemed necessary for protecting, challenging or enforcing the legal rights of us, our users, or our partners. Unless required by law, we will not be required to notify you of any such disclosure.


6. Personal information security
We take reasonable security measures to protect your information from any alteration, loss, misuse or any unauthorized access as far as practically possible. We stringently request that our partners always act in compliance with information protection legislation applicable and grant special attention to confidentiality of this information.

But we do not warrant or represent that your information will be protected absolutely against alteration, loss, or misuse by third parties. And any method of transmission over the Internet is not secure absolutely. Please be careful of your security to use the Internet by yourselves.

7. Specific provisions for users under GDPR or the equivalents
7.1. Accessing and correcting your information
At any time, you may contact us at the address provided in the “Contact” section herein and request to access the personal information that we hold about you. We may need to ask you to provide certain information to make sure you are who you claim to be. If you find the information on your account is not accurate, complete or updated, then please provide us with the necessary information to correct it.

7.2. Withdrawing your consent
Whenever we rely on your consent, you have the right to withdraw that consent at any time.
Please contact us if you would like to withdraw your consent to the processing of your personal information. Exercising this right will not affect the lawfulness of processing based on consent before withdrawal.

7.3. Erasing or restricting access to your information
You may request to delete or restrict access to your personal information. We may postpone or deny your request if your information is in current use for providing services or for other legitimate purposes, in which case we will let you know why we are unable to do so.

7.4. Transferring your information (your right to data portability)
You have the right to receive your personal information that you have provided us in a structured, commonly used and machine readable format and the right to transmit that data to another party of your choice, where technically feasible. However, this right shall not apply where it would adversely affect the rights and freedoms of others.

7.5. Transfer of your information outside your country
We may transfer information that we collect about you to affiliated entities, or to other partners across borders and from your country or jurisdiction to other countries or jurisdictions around the world, including those located in the United States of America and Japan. Please note that these countries and jurisdictions may not have the same data protection laws as your own jurisdiction.

7.6. Data retention period
We retain your information for as long as needed to provide you services, unless we are required by law to delete or if we accept your request to delete the information. We will also retain and use your information as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements.


7.7. Our policy regarding children
We do not knowingly collect or solicit personal information from anyone under the age of 16 or knowingly allow such persons to use our services. If you are under 16, please do not send any information about yourselves to us, including your name, address, telephone number, or email address. We are afraid to say that you must not use our services if you are under 16 years old.

7.8. Complaint to a supervisory authority
In accordance with Article 77 of the GDPR, you may also make a complaint to the Information Commissioner’s Office, or the data protection regulator in the country where you usually live or work, or where an alleged infringement of the GDPR has taken place.

8. Contact
You may contact our Data Protection Officer at hc+privacypolicy@geishatokyo.com or the address below for further information.

Geisha Tokyo, Inc.
Nakagawa Bld. 202, Yushima 3-31-1, Bunkyo-ku, Tokyo, Japan, 113-0034

9. Changes to this policy
We may update this policy. We encourage you to check back frequently to see any updates or changes to this policy. Please note that if we need to adapt the policy to legal requirements, the new policy will become effective immediately or as required.

Effective Date: November 8, 2018