Privacy Policy

Gravity Game Arise Co., Ltd.
PRIVACY POLICY (For EU and UK Residents)
(Effective Date: December 22, 2020)

1. Introduction

We take privacy seriously, and we are committed to protecting personal data which is defined in Article 4(1) of the GDPR
(the “Personal Data”) of our users (“you” or “User”) who reside in the territory of the European Union and further
including Iceland, Liechtenstein, Norway (The European Economic Area) and the UK who are under General Data Protection
Regulation (the “GDPR”), including any subsequent laws mandating data protection. This Privacy Policy (the “Policy”),
which is based on the principles set forth the GDPR, describes the full scope of purposes and reasons for collecting and
processing of Personal Data, determines and limits what Personal Data we collect and how we use it (several sections
below), how long we store it (is covered in each section devoted to the specific data), who has access to it, and what
rights and other control mechanisms are available to you as a User. This Policy applies where we are acting as a data
controller concerning your data and is limited to data collected or received by us through your use of our Services
(defined hereinafter)..

2. Who We Are

Gravity Game Arise Co., Ltd. (“Controller”), jointly with Company’s affiliates and independent contractors
(“Co-Providers”, collectively with Controller, “us,” “our,” or, “we”), provide mobile games(“Games”) and related
services, including, without limitation, online communities for Game or social network services offered by us via
service market company such as Google Play Store or App Store (“Service Markets”) (collectively, our “Service(s)”).
For clarity, Controller in the sense of the GDPR regarding the Services is:
Company Name: Gravity Game Arise Co., Ltd.
Official Address: 2F, 3-14-4, Hatchobori, Chuo-ku, Tokyo, Japan,
Phone: + 81 – 3 – 6263 – 2656
Contact Email: fm@gravityga.co.jp

The EU Representative of Controller under Art. 27 of the GDPR can be contacted at:
Company Name: The DPO Centre (Europe) Ltd.
Official Address: Alexandra House, Ballsbridge Business Park, Ballsbridge Park, Merrion Road, Dublin, Ireland, DO4 C7H2
Phone: +353 1 631 9460
Contact Email: eu-rep@gravityga.jp
Further, our data protection officer can be reached at:
Name : Martin Ok
Email : king@gravity.co.kr.
Address: 15F, Nuritkum Square Business Tower, 396, World Cup buk-ro, Mapo-Gu, Seoul, Korea,

3. Purpose of Our Collecting Personal Data

The Game, once downloaded via google play store or iTunes, is operated without communication between User’s device and
Controller’s server, therefore, Controller process Personal Data within limited cases to perform the agreement concluded
between you and us and according to Article 6(1) of the GDPR. We, if any, process Personal Data for the following
purposes;

• to communicate with you to resolve any problem you faced while using our Services or Game;
• to provide support, as well as technical support, including, but not limited to, Game and Services updates,
  product patches and fixes and other similar communications;
• for compliance with legal obligations that we are subject to (e.g., our obligations to keep certain information
  under tax laws);
• for the purposes of the legitimate and legal interests of us or a third party (e.g., the interests of other
  customers of ours), except where such interests are overridden by your prevailing legitimate interests and rights;
• to improve our Services and Game, as well as while requesting your feedback about our Services and Game.

The scope and purpose of the processing of your Personal Data, among other conditions for the processing, is specified
in this Policy. We will notify you about any significant changes in our Policy.

We do not collect special category personal data concerning Users’ racial and ethnical origin, biometric data, health
data, their political, religious or philosophical beliefs, trade union membership, genetic, health or sex life among
other Personal Data that is sensitive to fundamental rights and freedoms. You should be aware that in case you at your
own discretion post (publish) your Personal Data on, if any, forums, game chats or groups in social network related to
our Services or the Game or use them as your login or as character’s names (disclose), your data becomes available and
known to the public and you become solely responsible for the consequences of such disclosure.

4. Personal Data Processed For Our Performance of Services

Your Personal Data may be collected and processed by us or Service Markets for the purposes related to providing to
Users of our Services. For these purposes, we require and collect the following Personal Data (the “Compulsory Data”):

(1) Obligatory data, such as:

Compulsory Data is e-mail.

Compulsory Data is required for us to provide Services and the Game to Users and perform other obligations under the
agreements concluded with Users. Request for erasing of such data may result in your inability of using our Services as
set forth in below.

Compulsory Data may be collected through, namely:

• through, indirectly by Service Markets, registration with Services and/or with the Game;
• while contacting us via e-mail, fax, phone or mailing address of ours;
• while contacting our support team or otherwise;
• while using the forum, chats related to Services and/or the Game;
• while using Services and/or the Game otherwise (including information you provide to when participating in
  competitions, contests, and tournaments or responding to surveys, e.g. your contact details);

Additional data (“Additional Data”) that may be additionally collected by us for the execution of the agreement made
with Users related to the use of Services and the Game. Additional Data may be:

place of User’s residence (location) and

• cell phone number
• full name
• date of birth
• partial number of User’s ID
• IP address

The Additional Data, if any, is not obligatory to provide by Users to us, is collected and saved for using the Game.
Such Additional Data may also be collected to ensure security and confidentiality of your account. We will inform you
about it through Services, the Game, or other means of communication.

We, if any, may also collect other personal information (the “Non Personal Information”) which is not included in the
Personal Data of Users and store it separately from the Personal Data as described below in the Policy. Our advertise
partner(s) may process anonymous data, aggregated or not, to analyze and produce statistics related to the habits, usage
patterns, as a group or as individuals. Such anonymous data does not allow the identification of the customers to which
it relates. Anonymous data, aggregated or not, may be shared with third parties.

Be also aware, that for the purpose of organization of game process, we may collect information about your in-game
activities, logs, and data on in-game transactions. This data is used for detection, investigation, prevention and,
where applicable, and stored only for the minimum amount of time, needed for this purpose, namely, during the Legal
Retaining Period (as defined below). If the data indicates that a violation has occurred, we may further store the data
for the establishment, exercise or defense of legal claims during the applicable statute of limitations or until a legal
case related to it has been resolved. Please note that the specific data stored for this purpose may not be disclosed to
you if the disclosure will compromise the mechanism through which we detect, investigate and prevent such violations.
Also be aware that enjoying a certain User’s rights shall be in balance with rights and interests of other Users, as
well as lead to balance and should not affect the rights and freedoms of other parties, including trade secrets or
intellectual property.

We may keep, if any, records on correspondence with User, including support tickets along with other communications, for
statistics purposes, to deliver, develop and improve our Service and the Game, to support Users in using the Services
and the Game, to ensure security and confidentiality of the User’s account and data, to restore access to the User’s
account, Services and/or to the Game, to restore lost payments made by the User etc.

Such information, as specified in the table stipulated in Article 6. Retaining and Deleting Personal Data of this
Policy, is stored for the validity period of relevant agreements with us and 1 year after the termination of such
agreements (the “Legal Retaining Period”), including the Terms of Services unless there is a legitimate reason for a
longer processing.

Anonymous data and Non Personal Information of Users are kept separately from Personal Data and stored for no longer
than the validity period, which is decided based on the Legal Retaining Period, of relevant agreements with us.

(2) Payment Data

When the User tops up his or her Game account or makes payments via Service Markets, we and the Service Markets that is
chosen by the User to process the payment exchange with the following Payment Data:

• user ID from our billing system
• user ID in the payment system
• payment (transaction/order) ID
• date and time of payment (transaction/order)
• amount of payment (transaction/order)
• the currency of payment (transaction/order)
• signature of the authenticity of the request (payment) and

Additional Data in case credit cards are used for payment purposes may be:

• name of the cardholder;
• masked card number – 6 symbols and last 4 digits;
• country code (if applicable);
• address (if applicable).

Such Additional Data regarding credit card payment as mentioned is provided by the User directly to the payment systems
under the terms of use of such system that the system may require Users to enter before processing the payment. We do
not process such Additional Data.

The storage period of the Payment Data, as specified in the table stipulated in Article 6. Retaining and Deleting
Personal Data of this Policy, is 5 years as required under applicable law.

(3) Process for promotional purpose

We may use your Personal Data, to send, if any, promotional or marketing information and news about the planned
contests, promotions and similar events, news about our Services and the Game. If you do not wish to receive such
information, you can unsubscribe from receipt of such information following the instructions as described in the
corresponding messages or Game account interface.

(4) Process for Service notification purpose

We may use your e-mail and/or phone for sending notifications or other notifications, for example, in case of
communication within the scope of response to your requests or other communications related to access to Our Services
and/or the Game, password restoring or otherwise restoring access to the User’s account. For clarity, you may switch off
our notification especially via phone communication according to relevant guide.

(5) Process of Non-Personal Data for improvement and development

To provide quality Services and to justify your expectations of Our Services and/or Game, we or Service Markets or our
advertise partners may collect anonymous data:

• name and version of the operating system,
• the size of RAM
• the size of available disk space
• parameters of the network channel and internet connection such as network bandwidth and delay from User’s computer
  to our servers, traceroute information between

your PC and our servers, etc.

• other data that is mentioned in the Technical requirements to the Game

We may collect information about your Game’ preferences, progress in Game, playtime, as well as information about device
settings, unique device identifiers, and crash data. We process and store such data also to evaluate development plans,
provide updates to the Services and Game, bug-fixing.

Such information, as specified in the table stipulated in Article 6. Retaining and Deleting Personal Data of this
Policy, is stored for the validity period of relevant agreements with us and 1 year after the termination of such
agreements unless there is a legitimate reason for a longer processing.

(6) Process of IP Cookies for analyzing your use of Services

We may use Google Analytics provided by Google, Inc. (“Google”). Google Analytics uses “cookies.” The information
generated by the cookie about the visitors’ use of the website will generally be transmitted to and stored by Google on
its servers.

Furthermore, Users can prevent the collection of data generated by the cookie, and the processing of data by Google, by
downloading and installing the browser plug-in through the following link: https://tools.google.com/dlpage/gaoptout?

(7) Process of game data for the prevention of illegal user’s access

We may collect data for the organization of the game process and collect information about your in-game character
activities, logs, and data on in-game transactions. We may also collect Game data and commands the so-called log files
(information on the actions made by the character in the Game generated by the software, fixed in symbolic non-personal
form), as well as the content of in-game chats (correspondence). We may use this data for decisions to ban a Game
account or user’s character, according to the rules of the relevant Game.

Such data are not Personal Data and, as specified in the table stipulated in Article 6. Retaining and Deleting Personal
Data of this Policy, stored for 1 year from the moment it is collected.

If any, the Game account or character was banned based on logs or chat correspondence, such data, as specified in the
table stipulated in Article 6. Retaining and Deleting Personal Data of this Policy, is stored for 3 years after the
violation unless there is legitimate ground for a longer processing.

In case of dispute with the User, log files and chats are stored during the period of the dispute.

In the event of litigation between the User and us or in case we receive a request from competent authority, such data
can be combined with the personal information you provide and are stored during the period of resolution of the dispute.

(8) Security Measures

We endeavor to implement sufficient and up to date technical and organizational security measures to protect your
Personal Data against accidental or unlawful destruction, alteration or loss, unauthorized disclosure, or access. We,
affiliates and third parties authorized to access the Personal Data, are required to give the undertaking to maintain
such confidentiality and secrecy.

Further, when your Personal Data is shared with our affiliates ad subsidiaries, we guarantee an adequate level of
Personal Data protection, including but not limited to, by entering into standard data protection clauses adopted by the
European Commission with our affiliate and subsidiaries, as well as such third parties. We will provide you with a copy
of the standard data protection clauses upon your request.

Among other measures, any information sent to us is encrypted (scrambled) using high qualified technology. This is
industry-standard encryption technology that protects your data while being sent over the Internet from being
intercepted and misused by third parties.

We have put in place, and regularly review and update, appropriate physical, electronic, and managerial procedures to
keep personal data safe and help prevent unauthorized access, maintain data security and correctly use the information
collected.

Despite our efforts to enhance the security level of the Service, we cannot guarantee that unauthorized access, hacking,
data loss, or other breaches will never occur. We strongly encourage you not to share your account password with any
third parties for any reasons. Also please note that email and messaging systems are not considered secure, so we
discourage you from sending us Personal Data through these mediums. If you have questions regarding the security
measures of the Service, please contact our specialists at fm@gravityga.co.jp.

5. Sharing of User’s information

We do not transfer your Personal Data to anyone, except for those specified in this Policy or as provided by the rules
into force and this may be related to the provision of Our Services and performance of contracts you have concluded with
us. If such transfer to third parties is related to any other purpose, we will ask for your explicit consent to such
transfer.

We do not sell your personal information and do not receive benefits from any treatment of your data. We do not use your
data for advertising or promotion of products and services of third parties, other than those listed here.

We may share your data with the following categories of third parties.

(1) Regarding Payment systems, we may share your Personal Data such as:

Email address, IP address, information about in-game purchases, and other information you provide to us for the purpose
of fulfilling your purchase. The list of payment methods (payment systems, payment agents) that may be used by the User
for payments and with which we may share your data are described at our Sites. The specific list of the entities who
access the Personal Data to process the payment, the place where the transferred Personal Data is stored and the
relevant contract name based on which the Personal Data is transferred are as followed.

(2) With advertising partners, we may share your Personal Data such as:

Nickname, IP address and other information for targeting, delivery, and measurement of online advertising, or otherwise
facilitate transmittal of information that may be useful, relevant, or of interest to you.

(3) With data storage partners, we may share your Personal Data

Some of the information is stored using third-party data storage services.. We provide personal information to our
affiliates and other trusted businesses or persons to process it for us, in compliance with our Privacy Policy and any
other appropriate confidentiality and security measures. The specific list of the entities whose information storage
service is used for the custody of Personal Data, the place where the transferred Personal Data is stored and the
relevant contract name based on which the Personal Data is transferred are as followed.

The data is stored separately. Your data may be combined with other data collected by us in exceptional cases, for
example, in case of a violation by users of the agreement with us or the rules of the game, the availability of a
dispute between us and the User, conduct of financial control and accounting, etc. As for the detecting violations, be
aware that we use anti-cheating tools that collect information about the processes in use while you are accessing Game.

The User can modify and/or erase the data provided to them, except for those specified in this section as unalterable.
The user may edit his personal information having access to his private account. All changes are logged.

(4) With Game developers and right holders, we may share such data as:

Non-personally identifiable information publicly and with our partners – like developers or rights holders. This
information includes as a minimum your ownership of the game in question. It may also include your progress in the game,
achievements you have completed, your multiplayer game matchmaking information, in-game items and other information
needed to analyze, improve and fix game-related issues. We pseudonymize data to reach the only goal of upgrading the
service level.

(5) For publicly available information

We may also have message boards, forums and/or chat areas, where users can exchange ideas and communicate with each
other. When posting a message to a board, forum, or chat area, please be aware that the information is being made
publicly available on-line; therefore, you are doing so at your own risk. If your personal information is posted on one
of our community forums and you want to remove such information, please inform us with request to its removal. If we may
not be able to remove your personal information promptly, we will let you know about the reasons.

(6) With Anti-cheat and anti-fraud companies,

We may decide to share the information required for our detection, investigation, and prevention of cheating in the Game
and violations of agreements related to the Game only for the purposes of detection, investigation, and prevention of
cheating in the Game.

(7) With our subsidiaries and affiliates,

As a global company, we collect information that may be processed in our offices worldwide. Your information may also be
processed outside of the European Economic Area, e.g., in the United States of America, Japan, Taiwan, Thailand,
Indonesia or any other country in which we, our affiliates or subsidiaries maintain presence.

When your Personal Data is shared with our affiliates and subsidiaries, we guarantee an adequate level of Personal Data
protection, including but not limited to, by entering into standard data protection clauses adopted by the European
Commission with our affiliates and subsidiaries, as well as such third parties. We will provide you with a copy of the
standard data protection clauses upon your request.

(8) When our control is changed

We may share your data as part of our company’s sale, merger or change in control, or preparation for any of these
events. Any entity which buys us, or part of our business will have the right to continue using your Personal Data, but
only in the manner set out in this Privacy Policy unless you agree otherwise.

6. Retaining and Deleting Personal Data

We retain your information only for the period of time as necessary to achieve the particular purpose for which the
information was processed. Typically, without your request to erase Personal Data and also without legitimate reason to
keep it longer, we retain your information for 1 month after deregistration of your Game Account or for the duration
described in the table below:

Personal Data cannot be erased or anonymized when it is necessary to comply with the law. If you wish to change and/or
erase your Personal Data, you can submit such request to our specialists at fm@gravityga.co.jp. Please be aware that if
you have valid agreements on using our Services and/or the Game and submit the request on erasing and/or anonymization
of your Personal Data, you may lose the ability to use our Services and the Game from the date when your request is
completed.

When your data is incorrect or inaccurate, you must either amend it on your own or ask our specialists at
fm@gravityga.co.jp.

If we find that you provided incorrect or inaccurate Personal Data, it may restrict (ban) your Game account until you
amend it.

Payment data cannot be changed and/or erased at your request unless you provide us with the documented proof of the
necessity to make such changes.

We do not erase the data if any violation or abuse has been occurred by Users or we have been summoned not to erase the
data at competent authority’s request or court order. If a User requests the erase of the Personal Data, while a prior
request (s) from that User is still being processed, such data can be erased only when the User has recalled/canceled
all previous requests.

The data is stored separately in the place stipulated in Article 5(3) hereinabove based on the agreement executed with
data storage partners. Your data may be combined with other data collected by us in exceptional cases, for example, in
case of a violation by users of the agreement with us or the rules of the game, the availability of a dispute between us
and the User, conduct of financial control and accounting, etc. As for the detecting violations, be aware that we use
anti-cheating tools that collect information about the processes in use while you are accessing Game.

The User can modify and/or erase the data provided to them, except for those specified in this section as unalterable.
The user may edit his personal information having access to his private account. All changes are logged.

7. Transfer of Personal Data to Third Country

Your Personal Data may be transferred globally, either within or outside the European Economic Area (“EEA”), including
to a country or territory that may not have equivalent data protection standards. In all cases, appropriate security
measures for the protection of Personal Data will be applied in those countries or territories, under applicable data
protection laws.
9. Our Policy Concerning Children
Children who reach the age (“Competent Age”) to give valid consent, which may be various under his/her relevant national
law, can only use our Game or our Services with valid consent from their legal representative (e.g. parents). We make
reasonable efforts to verify if consent from or any contract concluded with such children is valid by offering users age
verification methods and by obtaining clear consent from children’s legal representatives. If we learn that we have
inadvertently gathered Personal Data from such children, we will take reasonable measures to promptly erase such
information from our records. If children under Competent Age or their legal representative ask us to cease processing
or profiling of the child’s Personal Data for the purposes of direct marketing, we will immediately do so. For that
purpose, you may contact us at fm@gravityga.co.jp

8. Your Privacy Rights

(1) Right to Access

You are entitled to confirmation as to whether or not we process your Personal Data and, where we do, access to the
Personal Data, together with certain additional information. You can access your Personal Data by logging into your Game
account or contacting us at fm@gravityga.co.jp.
To manage the information we receive about you from an SNS, you should change your privacy settings on the SNS under any
applicable policy of the SNS.

(2) Right to Rectification

You are entitled to have any inaccurate Personal Data about you rectified and, taking into account the purposes of the
processing, to have any incomplete Personal Data about you completed. You may change or update the profile information
by logging into your Game account or by contacting us at fm@gravityga.co.jp.

(3) Right to Erasure

In some circumstances, you are entitled to the erasure of your Personal Data without undue delay. Those circumstances
include: (i) the Personal Data are no longer necessary in relation to the purposes for which they were collected or
otherwise processed; (ii) you withdraw consent to consent-based processing; (iii) you object to the processing under
certain rules of applicable data protection law; the processing is for direct marketing purposes; and (iv) the Personal
Data have been unlawfully processed. However, there are exclusions of the right to erasure. The general exclusions
include where processing is necessary: (a) for exercising the right of freedom of expression and information; (b) for
compliance with a legal obligation; or (c) for the establishment, exercise or defense of legal claims.
If you choose to terminate or delete your Game account, we will immediately delete your Game account information.
Even after your account is terminated or deleted, some or all of your information may still remain visible to others,
including but not limited to any information that has been incorporated into any User contents or copied, stored or
disseminated by you or other users.
If a User requests the erase of the Personal Data, while a prior request (s) from that User is still being processed,
such data can be erased only when the User has recalled/canceled all previous requests.
You may request the erasure of your information by contacting us at fm@gravityga.co.jp.

(4) Right to Restrict Processing

In some circumstances, you are entitled to restrict the processing of your Personal Data. Those circumstances are: (i)
you contest the accuracy of the Personal Data; (ii) processing is unlawful, but you oppose erasure; (iii) we no longer
need the Personal Data for the purposes of our processing, but you require Personal Data for the establishment, exercise
or defense of legal claims; and (iv) you have objected to processing, pending the verification of that objection. Where
processing has been restricted on this basis, we may continue to store your Personal Data. However, we will only
otherwise process it: (a) with your consent; (b) for the establishment, exercise or defense of legal claims; (c) for the
protection of the rights of another natural or legal person; or (d) for reasons of important public interest.
You may request the restriction of the processing of your information by contacting us at fm@gravityga.co.jp.

(5) Right to Object to Processing

You have the right to object to our processing of your Personal Data on grounds relating to your particular situation,
but only to the extent that the legal basis for the processing is that the processing is necessary for: the performance
of a task carried out in the public interest or in the exercise of any official authority vested in us; or the purposes
of the legitimate interests pursued by us or by a third party. If you make such an objection, we will cease to process
the Personal Data unless we can demonstrate compelling legitimate grounds for the processing which override your
interests, rights and freedoms, or the processing is for the establishment, exercise or defense of legal claims.
You may object to the processing of your information by contacting us at fm@gravityga.co.jp.

(6) Right to Object to Processing for Direct Marketing Purposes

You are entitled to object to our processing of your Personal Data for direct marketing purposes (including profiling
for direct marketing purposes). If you make such an objection, we will cease to process your Personal Data for this
purpose.
You may object to the processing of your information for direct marketing purposes by contacting us at
fm@gravityga.co.jp.

(7) Right to Data Portability

To the extent that the legal basis for our processing of your Personal Data is:

• – consent; or
• – that the processing is necessary for the performance of a contract to which you are a party or to take steps at
  your request before entering into a contract,

and such processing is carried out by automated means, and you have the right to receive your Personal Data from us in a
structured, commonly used and machine-readable format and the right to have your Personal Data transmitted to another
controller. However, this right does not apply where it would adversely affect the rights and freedoms of others.

You may request to receive your information by contacting us at fm@gravityga.co.jp.

(8) Right to Complain to a Supervisory Authority

If you consider that our processing of your Personal Data infringes data protection laws, you are entitled to file a
complaint with a supervisory authority responsible for data protection.
You can find more details of the supervisory authority in your country by visiting
http://ec.europa.eu/newsroom/article29/item-detail.cfm?item_id=612080

(9) Right to Withdraw Consent

To the extent that the lawful basis for our processing of your Personal Data is consent, you have the right to withdraw
that consent at any time. Withdrawal will not affect the lawfulness of processing before the withdrawal.
You may withdraw your consent at any time in the Game setting or contacting us at fm@gravityga.co.jp.
You may also exercise any of your rights concerning your personal data by written notice to us at fm@gravityga.co.jp.

10. Change/Update to Privacy Policy

We may amend, at our discretion, any portion of this Privacy Policy at any time by posting or displaying the amended
Privacy Policy within and/or on the website. You will be deemed to have accepted such amendments by continuing to use
the Service. Except as otherwise stated, any such amendments will be automatically effective after they are initially
posted. Our policy will be regularly updated. We will notify you of the changes where required by law to do so. This
policy was last updated on December 22, 2020.

11. Links

The Service may contain links to other websites. The fact that the Service links to a website or presents a banner ad or
other type of advertisement does not mean that we endorse or authorize that third party, nor is it a representation of
our affiliation with that third party. We are in no way responsible for the privacy policies of these other websites to
which you choose to access from the Services. It is your responsibility to read the privacy policies of these other
websites when exiting the Services.

12. Questions

If you have any questions regarding our Privacy Policy and/or practices, please email us at fm@gravityga.co.jp.

Gravity Game Arise Co., Ltd.
PRIVACY POLICY (For Non-European Users)
(Effective Date: Dec 22 2020)

Gravity Game Arise Co., Ltd. (“Company,” “we,” “us” or “our”) maintains this Privacy
Policy (“Privacy Policy”) that summarizes our policies and processes on how we collect, use, disclose, transfer
and store your personal information. The Privacy Policy applies only to the collection, use and storage of personal
information that you may decide to provide to us in your use of: (1) our website(s) (our “Sites”), (2) our
applications for mobile platforms or devices and our web applications accessible on social networking services
(“SNS”) (collectively, our mobile and web applications are referred to herein as, the “Applications”), (3)
our game publisher networks, crowdsourcing service and platforms (collectively, “Networks”) provided in
connection with Applications and third-party applications utilizing our Services (“Third-Party Mobile
Applications”) and (4) chat rooms, blogs, web forums, messaging boards or other public forums in Applications and
our Sites (collectively, our “Forums”). The Applications, Networks, Sites, and Forums are referred to herein
collectively, as the “Services.”

PLEASE NOTICE THAT THIS PRIVACY POLICY REGULATES THE PROTECTION FOR THE PERSONAL DATA OF NON-EUROPEAN USERS WHO USES
OUR GAME SERVICE. FOR YOUR CONVENIENCE, EUROPEAN USERS MEAN THE USERS WHO RESIDE IN THE TERRITORY OF THE EUROPEAN
UNION AND FURTHEHR, INCLUDING ICELAND, LIECHTENSTEIN, NORWAY (THE EUROPEAN ECONOMIC AREA) AND THE UK. FURTHER, THE
COMPANY DOES NOT PROVIDE ANY SERVICES TO USER(S), DIRECTLY BY EXPORTING OR INDIRECTLY BY RE-EXPORTING, IN IRAN, NORTH
KOREA, CUBA, SYRIA, SUDAN, AND ANY OTHER COUNTRIES WHICH ARE UNDER U.S. SANCTION (“USER UNDER SANCTION’). THEREFORE,
PLEASE DO NOT ATTEMPT TO ACCESS OUR APPLICATIONS OR TO PLAY ANY GAME ON OR THROUGH OUR SERVICES IF YOU ARE A EUROPEAN
USER OR THE USER UNDER SANCTION.

Again, Company officially notifies that we do not provide any services to a European User and User Under Sanction. If
you are a European User or User Under Sanction, please do not attempt to access our Sites and Applications or to play
any game on or through any service of us. Further, if you newly acquire the nationality, or for any reason at all, by
which you become a European User or a User Under Sanction after your using our services, you should notify such fact to
us for our terminating your access to our services under the condition of the User Agreement and this Privacy Policy.

By accepting our Privacy Policy and the applicable Terms of Service during Service account registration or by otherwise
accessing or using our Service(s) you agree to the terms and conditions of this Privacy Policy (including our
collection, storage, use and disclosure of your personal information) and that your access or use of the Service(s) is
also subject to the applicable Terms of Service.

Collecting Personal Information

Our primary goal in collecting the information described below is to provide you, the user, with a customized experience
on our Service and to deliver better service, products, and more relevant content to our customers, prospective
customers, and visitors.

1. Personal Information We Collect

Personal information may be collected from you during your use of the Service, including, during (a) the registration
process, (b) promotional campaigns, (c) customer support and technical service requests, and/or (d) ordering and use of
products and other services, or from and through third-party service providers and partners.

Information Collected Directly From You

Registration Information. When you communicate directly with us, either through an Application, at our Site, a
Network, or Forum, you are authorizing us to collect, store and use/share information collected from you in accordance
with this Privacy Policy. Such information may include: (i) your age or birthday; (ii) your first and last name; (iii)
your valid e-mail address and telephone number; (iv) password and other information necessary to ensure security of your
account; and (v) such other information you choose to provide to us such as billing information, profile photo, photo
representation (avatar), character name, interests and hobbies, gameplay preferences, and links to profiles on various
SNS.

From time to time, we may expand or change the information requested upon registration or log-in, so this may not be a
complete list. We ask that you provide only your own personal information, not personal information concerning anyone
else.

Usage Information. We collect details of your use of our Services and the resources that you access. Such usage
information includes information about how and when you access or use our Services (such as Games accessed, game score,
pages visited, purchase and use of Virtual Money and/or Virtual Goods, the details of your purchases, and your
gameplay).

Interaction and Communications among Users. We collect information about (i) your interaction with other users
(for example, invite, gift, sharing of your rank or level, screen-shots, etc.) and (ii) your communication and
interaction with your contacts through social media channels (including, social network services, messengers, and any
other services which has social features like invite friends and sharing information with friends).

Information Through Mobile Devices. When you use an Application or Third-Party Mobile Application on your mobile
telephone or other mobile devices (“Mobile Devices”), in addition to such information described above, you are
authorizing us to collect, store and use/share the following information (as applicable): (i) Mobile Device type; (ii)
mobile carrier; (iii) Internet Protocol address; (iv) geographic location/country; (v) platform version; (vi)
navigation, interaction and engagement information regarding our users (vii) MAC address, International Mobile Equipment
Identity (IMEI), display resolution, time and date on screen of Mobile Devices and; (viii) such other information you
choose to provide to us. In addition, we receive and store information you provide when you sign up to have Short
Message Service (“SMS”) notifications set directly to your Mobile Device.

Payment and Billing Information. If you purchase any in-Service items, our third-party partners will collect the
payment and billing information necessary to complete the transaction. Such information may include: (i) your first and
last name; (ii) your valid e-mail address; (iii) credit card, PayPal and other third-party payment processor
information; (iv) billing address; and (v) such other information you choose to provide. Our third party partner may
also receive the foregoing information that you provide when you purchase Applications and Third Party Mobile
Applications through your Mobile Device.

Customer Service and Support. When you send email or other communications to us in connection with customer
service and support, we will collect and store your contact information, information about your use of the Service, your
user ID and such other information you provide to us in order to process your inquiries, respond to your requests and
improve our Service. We will also store the correspondence and any information contained therein.

Profile Information. We provide areas on our Service where you can post information about yourself and others and
communicate with others or upload content such as photographs. Such postings are governed by the applicable Terms of
Service. In addition, such postings may appear on other websites or services, or when searches are executed on the
subject of your posting. Also, whenever you voluntarily disclose personal information on publicly-viewable areas, that
information will be publicly available and can be collected and used by others. For example, if you post your email
address, you may receive unsolicited messages. We cannot control who reads your posting or what other users may do with
the information you voluntarily post, so we encourage you to exercise discretion and caution with respect to your
personal information.

Information Received from SNS and APIs

When you use an Application at an SNS, you allow us to access certain information from your profile through such SNS and
the applicable SNS platform Application Programming Interface (“API”). The information we receive varies by the
Application and by the privacy settings you choose for the SNS and may include any or all of the following information,
as allowed by you, the SNS and your privacy preferences: (i) your first and last name; (ii) your profile picture or its
URL; (iii) your user ID number; which is linked to publicly available information such as name and profile photo; (iv)
the user ID numbers for your friends that are also connected to our Application(s); (v) login e-mail you provided to the
SNS when you registered; (vi) your physical location and that of your access device(s) and (vii) your gender.

By using our Application(s) through an SNS, you are authorizing us to collect, store and use/share any and all
information you agreed the SNS could disclose to us through the API in accordance with this Privacy Policy. Your
agreement is evidenced when you “accept” or “allow” (or comparable terms) one of our Applications on an SNS.

2. How We Collect Personal Information

Automated Information Collection Technologies

As described below, when you access our Services, we collect certain technical information and may associate such
information with your user or account ID number for our internal use.

Cookies

A “cookie” is a small text file that is sent to your browser from a web server and stored on your computer’s hard drive.
We may use cookies to track general, non-personal information about our users (e.g., user name, pages viewed, time spent
on our Site(s), games, and the sites visited just before and just after our Site(s)) for statistical and market research
purposes.

We use cookies to gather information about our users’ browser activities in order to constantly improve our Service.
This information assists us to design and arrange our web pages in a most user-friendly manner and to continually
improve our Service to better meet the needs of our customers, prospective customers, and visitors.

We may also use local shared objects known as “flash cookies”, which help us to prevent fraud, remember your in-game
settings and to track your progress on certain in-game tasks.

You have choices with respect to cookies. By modifying your browser preferences, you have the option to reject all
cookies or limit the type of cookies you allow. Flash cookies operate differently from browser cookies and cookie
management tools available in a web browser will not remove flash cookies. To learn more about and manage flash cookies
you can visit www.adobe.com. Rejecting or
limiting the type of cookies may, however, in limited instances prevent you from accessing certain features on our
Service.

Log Files

Like most Internet services, we may also use log files on the server-side. The data held in log files includes your
computer’s or Mobile Device’s IP (Internet Protocol) address, browser type, browser language, e-mail application,
Internet service provider, referring/exit Web pages, computer platform type, date/time stamp, and user activity. Company
uses server log data to analyze trends, administer the services offered through our Service. We and our third-party
partners may use this information for product and service improvements and in marketing and advertising services.

The software enabling our Services has associated log and temporary files that are stored on Company’s servers. These
files store your account information, preference settings, system notifications as well as other data necessary to
enable you to participate in our Service. Your information may also exist within regularly performed server backups.

Tracking Technologies

Our Services may utilize a variety of methods for tracking purposes, including web beacons (also known as Internet tags,
pixel tags and clear GIFs). Web beacons are small pieces of data that are embedded in images on the pages of websites to
analyze the traffic patterns, such as the frequency users visit various areas of our Services. Pixel tags may allow us
to advertise more efficiently by excluding our current users from certain promotional messages or identifying the source
of a new installation. These methods may involve transmitting information either directly to us or to another entity
authorized by us to collect information on our behalf. We also use these technical methods in HTML e-mails that we send
our guests to determine whether our guests have opened those e-mails or clicked on links in those e-mails. With web
beacon technology, the information that we collect and share is anonymous and not personally identifiable. It does not
contain your name, address, telephone number, or email address.

Third-Party Advertisers

Many advertisements are managed and placed on the service by third parties. These third-party advertisers may use
cookies, web beacons or similar automated information collection technologies on your computer or Mobile Devices to help
present, better target, and measure the effectiveness of their advertisements, by collecting non-personally identifiable
information when you click on or move your cursor over one of their advertisements. We may share certain non-personally
identifiable information about you as a user with certain third-party advertisers to help them deliver more relevant
advertisements through their ad networks. In some cases, we may have access to information from cookies, web beacons,
and similar automated information collection technologies used by third-party advertisers on our Services and this
information may permit us to identify other sites or services that you have visited that are also associated with the
third-party advertiser.

The use of cookies, web beacons, or similar automated information collection technologies by third-party advertisers is
subject to their own privacy policies. Finally, once you have clicked on an advertisement and have left the Service, our
Privacy Policy no longer applies and you must read the privacy policy of the applicable third-party advertiser to see
how your personal information will be collected, stored and used as part of their service.

Click-Through URLs

Some of our Services, including email messages, use “click-through URLs” linked to other content on our Services. We
track this click-through data to help us determine interest in topics and use of the Services.

Monitoring/Public Information

You may also choose to disclose personal information in our Forums. Personal information you disclose in such Forums is
public information, and there is no expectation of privacy or confidentiality. Please refer to the Terms of Service for
additional information relating to the disclosure of personal information in such Forums.

Other Sources

We may collect or receive information from other sources including other users of the Service and third-party
information providers and partners. For example, we receive and store the information you provide when you enter any
promotion, sweepstakes or loyalty program. Such information may be used to supplement your account information and/or
profile and may be combined with other information we collect from you.

Use, Disclosure, and Transfer

Unless otherwise described elsewhere in this Privacy Policy, we will not use or disclose any personal information
collected from you. Your personal information may be used alone or in the aggregate with information collected from
other users.

Use by Company

We use the information you provide so that we may better understand your needs and the needs of our customers,
prospective customers, and visitors. Specifically, we use your personal information for many purposes, including:

1. to allow you to register for and use our Services;
2. to apply for employment opportunities at the Company;
3. to audit and analyze data to improve and ensure the continued smooth operation of our Service;
4. for market research purposes, including, without limitation, to analyze user characteristics and usage patterns in
   order to better understand how our Services are used and market them more effectively;
5. to communicate with you concerning your account or to send you announcements, newsletters, promotional materials
   and other information about our Services or offerings of our business partners, and to offer you opportunities to
   participate in surveys, contest and sweepstakes;*
6. to prevent or investigate actual or suspected fraud, hacking, infringement, or other misconduct

involving our
Service;

7. to respond to inquiries, troubleshoot problems, investigate incidents, and handle complaints;
8. provide, maintain, protect and improve our Services, including keeping you posted on our latest Service
   announcements, software updates and upcoming events, and develop new services;
9. protect our rights or property or that of our users;
10. to satisfy any applicable law, regulation, legal process or enforceable government request;
11. to send notices, such as communications about your purchases and changes to our Terms of Service, this Privacy
    Policy and other Service-specific policies, and to enforce applicable terms and conditions set forth in such
    policies;
12. to enable user-to-user communications; and
13. protect against harm to the rights, property or safety of the Company, its users, or the public as required or
    permitted by law.

The Company processes personal information on our databases, equipment, and servers (owned by the Company and/or third
parties in Japan and in other countries). In some cases, we may process personal information outside of your country.

*If you decide at any time that you no longer wish to receive such communications from us, please follow the unsubscribe
instructions provided in any of the communications or follow the process described in the “Opt-Out Provision” section
below

Disclosure and Transfer to Third Parties

We generally do not disclose or transfer any personal information about our customers, prospects, or visitors to any
third parties. We may however, disclose and transfer data which does not contain or reveal any personally identifiable
information or is specifically attributable to you to our business partners, third-party analytics service providers, ad
networks and advertisers (collectively, “Partners”). Provided, however, some Partners may also act as third-party
service providers (described below) to us and may have access to your personally identifiable information. Moreover,
Partners may obtain public information about you from your profile or other public sources.

We may also periodically engage in co-marketing activities, where we work with a complementary solution provider to
launch a joint marketing program. In these situations, we will only send information to you on behalf of the other; we
do not provide your personally identifiable information to such a partner. We may also enter into business partnerships
with other parties to provide specific services. If a user signs up for these services or responds to a particular
marketing offer, we may share personally identifiable information such as your name or other contact information that is
necessary for our business partner to provide these services or get in contact with you.

Disclosure of your personally identifiable information may occur when we engage or employ service providers, vendors or
other third parties to facilitate the provision of our Services (including, without limitation, payment processing, data
analysis, e-mail delivery, hosting services, customer service, and promotional services) to provide the Services on our
behalf, or to assist us in analyzing how our Services are being used. Such third party service provider (“Third Party
Partner”) may have access to your personally identifiable information only to perform these tasks on our behalf
and are obligated not to disclose or use it for any other purpose.

Currently, the name of Third Party Partner, services performed by it on our behalf, service territory of it, and period
of retention and use by it of Personal Information are as follows:

Google Admob
PrivacyPolicy：https://support.google.com/admob/answer/6128543?hl=en

UnityAds
PrivacyPolicy：https://unity3d.com/legal/privacy-policy

LastUpdate: May 15, 2020

In the event Company combines with another company in the future through a corporate merger, sale, acquisition,
liquidation or other similar process, your personally identifiable information may be transferred with the business or a
part of it, or maybe sold as an asset of the business, to the successor organization in such transaction. If material
changes to the Company’s privacy practices will occur as a result of such transaction, we will notify you and other
users in the manner described in this Privacy Policy.

In addition, upon the expiration or the termination of any third party license arrangements involving one or more parts
of the Service, your personal information (including name, email address and other personally identifiable information)
may be transferred to the subject third party licensor in accordance with the terms of the applicable license agreement.
In advance of such transfer to a third party licensor, the Company will notify you and other users in writing in the
manner described in this Privacy Policy.

Safety, Security and Legally Required Disclosures

Your personally identifiable information, and communications you make within the Service, may be accessed and disclosed
if we believe that our Service is being used in the commission of a crime, when we believe in good faith that there is
an emergency that poses a threat to the safety of you or another person and when necessary either to protect our rights
or property including to enforce our Terms of Service, or for us to render the service you have requested.

We may also disclose personally identifiable information when required by law, regulation, court order, or in response
to a subpoena or litigation discovery request, or in the good faith belief that such action is necessary in order to
conform to the edicts of the law or comply with a legal process served on us. In addition, we will make any legally
required disclosures to government authorities and provide notice to you of any breach of security, confidentiality, or
unauthorized release of personal or private data in accordance with applicable laws, rules and regulations.

Storage and Security

We employ reasonable measures (both online and offline) to protect the security of information we collect from you. Such
information is housed in secure databases, equipment, and servers located in Japan and/or in other countries. The
databases, equipment, and servers we utilize may be owned by third-party providers. To prevent unauthorized access,
loss, or misuse, maintain data accuracy and ensure the appropriate use of information, we have put in place physical,
electronic, and managerial procedures to safeguard and secure the information we maintain. We use industry-standard
technology, such as firewalls, in an effort to protect the confidentiality of your personal information. Moreover, in
addition to password protection offered in connection with your Service account, we encrypt your transmission of
sensitive information to us (e.g., account passwords and payment-related identifiable information) via SSL (secured
socket layer) protocol in the interest of heightened privacy protection and information integrity.

Although we take reasonable precautions against possible security breaches of our Service, databases, equipment or
servers, and records, we cannot guarantee that unauthorized access, hacking, data loss, or other security breaches and
factors beyond our control will never take place and result in disclosure of your personal information. Accordingly, we
disclaim any guarantees, warranties, or representations relating to maintenance or nondisclosure of any personal
information collected from you. We strongly urge you to take reasonable measures at all times (online and offline) to
protect your personal information, including your password and other sensitive information.

In addition, while we strive to protect your personal information, you should know that information sent over the
Internet, whether by e-mail or by using one of our on-line forms, is not necessarily secure against interception.
Therefore, we cannot be responsible for such interception and cannot guarantee the security of such information.

We will investigate, attempt to resolve, and take all reasonable steps necessary to ensure that your personal
information and data is treated securely and in accordance with this Privacy Policy.
We will retain your personal information for as long as is necessary to fulfill the purposes for which it was collected
or as needed to provide you with Services. We may retain your personal information after you have closed any account you
have with us or after we have ceased providing Services to you if retention of your Personal Information is reasonably
necessary to comply with our legal obligations, meet regulatory requirements, resolve disputes between members, prevent
fraud, cheating or abuse, or enforce this Privacy Policy or any other agreement we may have with a user.

Additional Privacy Policy Terms

Opt-Out Provision

When we first collect information from you, we will offer you the opportunity to opt-out of having your personal
information shared with parties outside of Company (unless otherwise described in this Privacy Policy). In addition, if
you do not want us to send you communications relating to our Services, including, without limitation, announcements,
newsletters, and promotional materials or offers to participate in surveys, contests or sweepstakes, you can opt-out at
the time of registration or information collection. If, at a later date, you choose to have your name or any other
personal information removed from our mailing list, you can do so by emailing (fm@gravityga.co.jp)

Review, Update, Correct, or Delete Personal Information

Generally, you may review, update, correct, or delete your personal information collected by or through our Service by
logging into your account. You may also correct factual inaccuracies. Certain types of personal information that is
necessary to check eligibility, such as birth date or age, cannot be deleted, but may be modified with sufficient
verification of the new information. Note that we reserve the right to terminate or delete any registration or
promotional entry if we believe the personal information submitted was knowingly false or fraudulent.

To delete your personal information, you may also email us at (fm@gravityga.co.jp). We will use commercially reasonable
efforts to honor your request.
Please be aware that even after your account is terminated or deleted, some or all of your information may still remain
visible to others, including but not limited to any information that has been: (i) incorporated into others user’s
content, comments, postings, submissions, cities, resources or other in-game assets; (ii) copied, stored or disseminated
by other users; (iii) shared or disseminated by you or others such as in a public posting; or (iv) posted on a
third-party platform. A request to delete and/or termination of your account will not result in the removal of
information collected and already put in aggregate form or information that cannot, in our sole discretion, be removed
without undue burden to us. We are not able and/or obligated to remove any of your information from a third party
platform.
Moreover, please be aware that even after you delete your account or your account is terminated, your information is not
deleted in its entirety from our servers and may not be deleted from servers of the third-party platform you use to
access our Services. We may, but are not obligated to, retain backup copies of your information, including personal
information on our servers or databases (and/or any authorized third-party servers or databases we use). Such
information may be disclosed pursuant to this Privacy Policy regardless of whether your account is deleted or
terminated. Moreover, any third party platform that you use to access the Services may also retain backup copies of your
information even after your account is deleted or terminated which may be used and/or disclosed in accordance with their
privacy policy.
To have access to your personal information, you must provide proof of identification such as full name, street address,
city/state and zip code, user ID and password, and/or information about your recent activity on our Service. We reserve
the right to deny access to any user if we believe there is a question about your identity. And if the burden or expense
of providing access to your personal information is disproportionate to the risks to your privacy, or if the legitimate
rights of others would be violated, we may decide not to provide access to such information. Moreover, we may still
retain an archived copy of your information in our files as required by law or for legitimate business purposes,
including, resolving disputes, enforcing the Terms of Service, and other technical and legal requirements and
constraints related to our Service.

To manage the information we receive about you from the SNS where you play our games, you will need to follow the
instructions at that SNS for updating your information and changing your privacy settings.

Notification of Changes

We reserve the right to update and change the terms of this Privacy Policy at any time. If we decide to update and
materially change the terms of our Privacy Policy, we will post those changes in our Services and/or on the applicable
Sites, and in the updated Privacy Policy. You should periodically check this Privacy Policy for updates.

By continuing to access or use the Services after we have posted an updated Privacy Policy or have provided you with
notice of a modification, you agree to be bound by the modified Privacy Policy. If the modified Privacy Policy is not
acceptable to you, your only recourse is to cease using the Services.

Links to Third-Party Websites, Services, and Offers.

Our Service may contain links to other websites, services and/or offers from third parties. We are not responsible for,
nor will it be liable to you or any third party for, your interaction with such third parties or the information
requests initiated by such third parties or the subsequent use, treatment, or dissemination of the information you
voluntarily chose to provide to them. You should review the applicable privacy policies and information practices of
such third parties carefully before providing personal information to them. Moreover, if you have any questions or
concerns, you should contact the third party directly.

Protection of Children’s Privacy

Company is committed to providing special protection for the privacy of children who may use our Service. The Service is
intended for use by persons aged 3 (three) and over. However, a minor or a legally incompetent under the local law can
only use our Applications or our Services with valid consent from their legal representative (e.g. parents or guardian,
“Representative”). We make reasonable efforts to verify if consent from or any contract concluded with such a minor or a
legally incompetent is valid by offering users age verification methods and by obtaining clear consent from
Representative(s). If we learn that we have inadvertently gathered Personal Data from such a legally incompetent, we
will take reasonable measures to promptly erase such information from our records.

Special Note to Parents

If you become aware that your child has provided us with personal information at our Service, we invite you to notify us
so that we may delete the information from our records and discontinue any related features or services (see Opt-Out
Provision above). We also urge parents to instruct their children never to give out their real names, addresses, or
phone numbers without parental permission when using the Internet. We appreciate your cooperation in assisting us to
provide a safe and enjoyable online experience for your children.

Users Outside Japan

The Company is a Japanese company, and Company’s business operations are primarily conducted in Japan. We operate our
company and administer this Privacy Policy under applicable laws and regulations of the Japan (“Japan”). If you use our
Service from outside Japan, you are thereby consenting for your personal information to be transferred to, stored in,
and be processed in Japan and/or in other countries by the Company and/or its Affiliates in the manner described in this
Privacy Policy. Your consent to this Privacy Policy followed by your submission of your personal information represents
your agreement to such transfer, storage, and processing of information.

As described elsewhere in this Privacy Policy, when you submit personal information via our Service, the information is
housed in secure databases, equipment, and servers located in Japan and/or in other countries. The databases, equipment
and servers we utilize may be owned by third-party providers.

Users in certain jurisdictions may have a right to access his/her personal information held by the Company and/or its
Affiliates. Your right of access to such personal information can be exercised in accordance with applicable laws,
rules, and regulations. Please submit any requests for such access to (fm@gravityga.co.jp).

Language

The controlling language of this Privacy Policy is English. If you have received a translation into any other language,
it has been provided for your convenience only. The English version of this Privacy Policy shall govern to the extent of
any inconsistency between the English version and any translated version.

Contact Us

If you have any questions, inquiries, requests, complaints, or comments regarding this Privacy Policy, or have other
questions or suggestions about our information practices, please contact us via e-mail at (fm@gravityga.co.jp).

© Gravity Game Arise Co., Ltd. All rights reserved.