Yunuo International Inc. (“We”) provide you with this Privacy Policy to describe how we manage information about users of our services.

1. Scope
The scope of this Privacy Policy is limited to information and data collected or received by us through your use of “Synaptic Drive” (“Game”).
For users in European Economic Area (“EEA”), we have some specific provisions to respect the General Data Protection Regulation (“GDPR”).

2. The information we collect
We collect and process the following information during your use our services:
- Data about your device setting, such as device model, operating system version, platform, region, language, screen resolution, etc.;
- Data about your access history, such as IP address, time stamp, etc.;
- Data about your activities on the Game, such as the game version, your game score, progress, friends list, etc.;
- Your account information, such as email address, your game ID, nickname, etc.; and
- Your contact information, such as name, email address etc. when you contact our customer support.

3. How we use your information
We collect and use the information listed above for the following purposes:
- To provide you with the Game and to create your account with the information;
- To enable communications between our users;
- To provide you with customer supports;
- To improve our existing services and to develop new services with analysis and research about your activities on the Game;
- To maintain our services secure and stable with monitoring suspicious or unexpected use;
- To send you notifications including confirmations, 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; and
- To investigate or address claims or disputes relating to your use of our services, or as otherwise allowed by applicable law, or as requested by regulators, government entities, and official inquiries.
4. Information sharing and disclosure
We may share the information above with third-party partners for the aforementioned purposes.
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.

5. Special information for users in EEA with respect to GDPR

5.1. 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 Game); or
(b) You have provided us with your consent to do so.
(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:
- Run, grow and develop our business;
- Operate, maintain and improve our Game and our marketing efforts;
- Understand the way in which our Game is used; and
- For internal administrative purposes.

5.2. Withdrawing your consent
Whenever we rely on your consent, you have the right to withdraw that consent at any time. Please contact us at the address provided in the “Contact” section herein 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.

5.4. 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.

5.5. 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.

5.6. 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 Japan. Please note that these countries and jurisdictions may not have the same data protection laws as your own jurisdiction.

5.7. 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.

5.8. 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.

5.9. Complaint to a supervisory authority
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.

6. Accessing and correcting your information
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. 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. Contact
You may contact our Data Protection Officer at [ sd-support-w@yunuo.co.jp ] or the address below for further information. We may need to ask you to provide certain information to make sure you are who you claim to be.

Yunuo International Inc.
23-1, Kanda Higashi Matsushita Cho, Chiyoda-ku, Tokyo, Japan, 101-0042

8. Updates to this Privacy Policy
We may occasionally update this policy. If we make significant changes, we will notify you of the changes through the Game or through others means, such as email. To the extent permitted under applicable law, by using our services after such notice, you consent to our updates to this policy. We encourage you to periodically review this policy for the latest information on our privacy practices.

Last Update:2019.12.25