Effective Date: June 24, 2025
The terms of this service agreement (hereinafter referred to as “this Agreement”) are for the “Umamusume: Pretty Derby” games and service operated and provided by Cygames, Inc. (hereinafter referred to as “Cygames”), and include the applications and other content that need to be installed when using the “Umamusume: Pretty Derby” service (together referred to as the “Services”). Capitalized terms not defined in the text of this Agreement are defined in Article 1.

By using the Services, you (“Customer”) agree to be bound by the terms of this Agreement. If you do not agree with the terms of this Agreement, please do not use the Services.

Article 1 Definitions
The following terms are used in this Agreement.
1. The “Customer” refers to the user of the Services provided under this Agreement.
2. An “Account” refers to the Customer’s information that is on file with Cygames and it is the identifier issued by Cygames to identify the Customer.
3. The “Individual Service Agreement” refers to the terms and conditions which are presented to each Customer, in addition to this Agreement, under names such as “agreement,” “guidelines,” or “policy” and to which the Customer’s use of the Services is also subject.
4. “Content” refers to the content that can be used, viewed, and accessed through the Services and includes text, audio, music, images, videos, software, programs, codes, Customers’ usernames, and other proprietary information.
5. “Device” means the device (including hardware and peripherals such as personal computers) with which the Customer uses the Services.
6. A “Fee-Based Service” refers to a service or Content that requires the payment of a usage fee by the Customer.
7. The “Game Currency” shall refer to fictional credits or currencies that may only be used exclusively within the Services.
8. “Game Items” means virtual items that may only be used exclusively within the Services.

Article 2 Consent to the Agreement
1. The Customer’s use of the Services is subject to the Customer consenting to the terms and conditions of this Agreement and the Individual Service Agreement. The Customer agrees to use the Services within the scope set forth by Cygames in accordance with the terms and conditions set forth by Cygames (e.g., age and usage environment).
2. In the event that the Customer does not consent to this Agreement or the Individual Service Agreement, the Customer shall not be entitled to use the Services, and shall immediately cease downloading, installing, or using the Services. In the event that the Customer has already installed the Services, the Customer shall uninstall the Services.
3. In the event that an Individual Service Agreement has been established in relation to the Services, the Customer shall use the Services in accordance with the provisions of the Individual Service Agreement in addition to this Agreement.
4. In the event that there is a discrepancy in the content of this Agreement and the Individual Service Agreement, the content set forth in the Individual Service Agreement shall be applied in preference.
5. For users under the age of majority in the country where they live: THE PARENT OR GUARDIAN MUST PROVIDE CONSENT TO THEIR CHILD’S REGISTRATION WITH OR USE OF THE SERVICES. THE PARENT OR GUARDIAN AGREES TO BE BOUND BY THIS AGREEMENT WITH RESPECT TO SUCH CHILD’S USE OF THE SERVICES. Additionally, users under the age of majority will be restricted from using some of the services of the Services.

Article 3 Changes to the Agreements and Disclaimers
1. Cygames reserves the right to amend this Agreement and/or the Individual Service Agreement (i) in the event that Cygames considers that amendments need to be made for legal reasons including any changes in laws, (ii) due to technical necessity, (iii) in order to maintain company operations, (iv) for the benefit of the user, and/or (v) if Cygames determines for any other reason, in its sole discretion, that such amendments are required.
2. Cygames shall inform the registered Customers about the proposed amendment via its website or in-game messages.
3. The Customer is entitled to object to any amendment of this Agreement or the Individual Service Agreement until the amendment becomes effective. Once the amendment becomes effective, the objecting Customer must immediately cease downloading, installing, and using the Services. In the event the objecting Customer has already installed the Services, the Customer shall uninstall the Services.
4. If the Customer does not expressly object to an amendment of this Agreement or the Individual Service Agreement or if the Customer uses the Services again after the amended terms and conditions become effective, it shall be deemed that the Customer consents to this Agreement or the Individual Service Agreement as amended.

Article 4 Handling of Personal Information
Cygames shall handle the personal information obtained from the Customer in accordance with the “Privacy Policy,” as set forth separately by Cygames.

Article 5 Limited License of Rights (e.g., Intellectual Property)
1. The Services are provided for the Customer’s enjoyment, and unless otherwise specified, solely for the Customer’s own personal use. Cygames hereby grants the Customer a personal, non-exclusive, non-transferable, non-sublicensable, limited license to access and use the Services and any game or Content included thereunder for the Customer’s own non-commercial entertainment purposes, subject to the Customer’s complete compliance with this Agreement. The Customer acknowledges that the time spent on or using the Services, including and without limitation on any underlying game or Content, is solely for the Customer’s personal entertainment purposes, and that no monetary value can be attributed to such time, and that, except for the license granted herein, the Customer is not entitled under the law to use or have access to the Services and/or the Content.
2. Between the parties, Cygames shall own all rights and titles in and to (i) the Content, including the text, software, images, programs, trademarks, logos, and any other features of the Content that is part of the Services, and (ii) all code, programming, and any associated patents or proprietary rights related to the Services or the underlying game. This Agreement shall not transfer any rights (e.g., intellectual property rights) relating to the Services to the Customer other than the right to access and use the Services set out in Article 5(1). The Customer acknowledges that Cygames’ intellectual property contained within the Content and the Services is valid and protected in all media existing now or developed later in the future, and acknowledges that the Customer does not acquire any ownership rights in or to the intellectual property.
3. Cygames does not grant the Customer any express or implied rights or licenses in or to the Services and/or the Content other than what is expressly set forth herein. Furthermore, the Customer may not modify, copy, adapt, reverse engineer, de-compile or otherwise reduce to a human-perceivable format, distribute, transmit, transfer, license or sublicense, publicly display, or sell in any form or by any means, in whole or in part, the Content.
4. Cygames reserves the right to modify, amend, and update the Content and the Services at any time and for any reason. The Customer agrees that Cygames will not be liable to the Customer or any third party for any such modification, suspension, or termination.
5. Cygames reserves the right to set, create, and change at its discretion the specifications, rules, design, audiovisual expressions, effects, parameters, scenarios, and all other matters in the Content and the Services.
6. The Content contains copyrighted material, trademarks, and other proprietary information, including videos, comments, articles, information, catalogs, brochures, data, text, software, photos, and graphics. The Content is subject to copyrights owned by Cygames and other individuals or entities and is protected by copyright laws.
7. The names, trademarks, service marks, and logos of Cygames belong exclusively to Cygames and are protected from reproduction, imitation, dilution, or confusing or misleading use under trademark and copyright laws. All other trademarks, service marks, and logos (including third-party product names) are the property of their respective owners. The use or misuse of the trademarks is expressly prohibited and nothing stated or implied in connection with the Services grants you any license or right under any patent or trademark of Cygames or any third party.

Article 6 Account and Password
1. The Customer will ensure that any username selected for the Customer’s Account does not include personal information, does not infringe on any third-party rights, and is not otherwise unlawful. Cygames reserves the right to refuse to grant the Customer a username for any reason, including if it potentially impersonates someone, is vulgar, is otherwise offensive, or may cause confusion. The Customer does not own any rights to the username and Cygames reserves the right to change or delete any username, with or without prior notice to the Customer, at any time and for any reason in its sole discretion.
2. The Customer acknowledges that the Customer does not have any ownership or proprietary rights to the Account. The Customer cannot transfer, loan, or pass on any of the usage rights in the Services to a third party.
3. To create an Account, we may require or request that you provide us with certain information, including personal information. When you decide to provide Cygames with your information, you agree to: (a) provide accurate information about yourself as prompted by the Account registration process and (b) maintain and update your information to keep it accurate and current. If any information provided by you is untrue, inaccurate, not current, or incomplete, Cygames has the right to terminate your access to and use of the Services.
4. Cygames shall bear no responsibility or liability for any issue that arises as a result of a defect or mistake in the information registered by the Customer when the Customer uses the Services, and the Customer releases Cygames from all liability or responsibility for any actions taken which relate to the incorrect information. THE CUSTOMER IS SOLELY RESPONSIBLE FOR MAINTAINING THE CONFIDENTIALITY OF THEIR USERNAME AND PASSWORD AND ALL ACCESS TO AND USE OF THEIR ACCOUNT, GAME CURRENCY, OR GAME ITEMS.
5. The Customer shall take all appropriate safety measures against the unauthorized use of the Account by any third party with reasonable care.
(1) The Customer shall in particular:
- safeguard the confidentiality of the Account’s username and password in particular when using national or international media, private correspondence, social media, or a service on the Internet, and not disclose such information to any third party;
- secure access to the hardware with which the Customer accesses the Services (e.g., by implementing further passwords necessary to unlock the hardware, which again the Customer shall safeguard in the ways described in this Agreement);
- safeguard any credit cards or other payment instruments which the Customer uses to effect payment for the Services against any unauthorized use by third parties;
- in case the Customer has parental authority over a minor,
● restrict the minor’s use of the Customer’s Account and
● monitor, on a regular basis, that the minor does not use the Customer’s Account in spite of the prohibition to do so.
(2) If the Customer breaches the obligations of this Agreement, he or she shall be liable according to the statutory damage claims and other claims permitted under relevant laws and regulations.
6. Cygames shall consider any acts performed by the Customer or by a third party on the Customer’s Account as the Customer’s own acts if the third party was able to use the Customer’s Account due to the Customer’s permission or fault. The Customer acknowledges that it is the Customer’s own responsibility to ensure that the information registered by the Customer when using the Services is not used in an unauthorized manner by a third party. It is the Customer’s responsibility to resolve any issue that arises as a result of the Customer releasing their Account details to a third party, whether by using national or international media, private correspondence, social media, a service on the Internet, or any other method. The Customer acknowledges that Cygames shall bear no responsibility for any such misuse.
7. As between the parties, the Customer shall bear all liability and responsibility for any acts performed in the Services through the Customer’s Account and username by the Customer or by a third party on the Customer’s Account and username as the Customer’s own acts if the Customer could have prevented the use of the Account by applying reasonable care and in particular by complying with the obligations of this Agreement.
8. If the Customer violates this Agreement and does not comply with a warning notice, Cygames reserves the right to delete or suspend the Customer’s Account and information associated with the Customer’s Account. All of the Customer’s usage rights in the Services shall cease to exist when the Account is suspended, deleted, or revoked, regardless of the reason.

Article 7 Provision of Service
1. Cygames reserves the right to change, suspend, or terminate at its discretion the Services and all the services provided using the Services.
2. If the Services are terminated under the preceding paragraph, the Customer cannot access the Customer’s Account once the Services are terminated.
3. The Customer is not entitled to a refund, return, or other repayment in circumstances where there has been a cancellation by the Customer of the Fee-Based Services other than to the extent that any such refund, return, or other repayment is required by applicable laws or regulations.
4. Notwithstanding any provision to the contrary herein, the Customer agrees that the Customer has no right or title in or to any Content, or Game Items, whether earned in the game or purchased from Cygames, or any other attributes associated with an Account or stored on the Services. THE CUSTOMER AGREES THAT GAME ITEMS HAVE NO CASH VALUE AND THAT CYGAMES HAS NO OBLIGATION TO EXCHANGE GAME ITEMS FOR ANYTHING OF VALUE. IF THE CUSTOMER’S ACCOUNT IS TERMINATED, OR SUSPENDED, GAME ITEMS AND THE ACCOUNT SHALL HAVE NO VALUE. Game Items may not be transferred, licensed, or sold.
5. Cygames reserves the right to charge fees for (or to provide at no charge or for promotion) the right to use Game Items.
6. To the extent that it is not inconsistent with the laws or regulations, Cygames has the right to modify or eliminate Game Items as it sees fit and in its sole discretion, and it will only be liable to the Customer for the exercise of such rights in cases of willful misconduct and gross negligence.

Article 8 Advertisements
Cygames shall reserve the right to post the advertisements of Cygames or a third party in the Services at the discretion of Cygames.

Article 9 Fees and Expenses
1. The costs pertaining to the purchase, introduction, and maintenance of a Device, the communication fees (e.g., data usage fees), and all other expenses necessary while using the Services shall be borne by the Customer. The Customer will pay all fees or charges incurred through their Account, including applicable taxes at the time that the fee becomes payable.
2. Cygames may change the price for functions that are free or fee-based in the Services at its sole discretion. The Customer acknowledges and agrees that the Customer may be unable to use the Services in whole or in part if the Customer does not accept the new price for functions.
3. THE CUSTOMER ACKNOWLEDGES AND AGREES THAT THE CUSTOMER IS FULLY LIABLE FOR ALL FEES AND CHARGES INCURRED OR MADE THROUGH THE ACCOUNT AND THAT, UNLESS OTHERWISE PROVIDED FOR HEREUNDER OR UNDER APPLICABLE LAW, THERE ARE NO REFUNDS FOR FEES AND CHARGES INCURRED OR MADE THROUGH THE CUSTOMER’S ACCOUNT.

Article 10 Fee-Based Services
1. It shall be possible to use the Services (except Fee-Based Services) for free, but the Customer may decide to use additional Fee-Based Services.
2. Fee-Based Services can only be used as long as the Services are provided. After the termination of the Services, the Customer cannot continue to use any Fee-Based Services.
3. The pricing of the Fee-Based Services shall be described before any purchase can be made. Cygames or a settlement agency (including but not limited to an intermediary platform holder) will have the right to amend or change the prices prospectively. If a price determined by Cygames or a settlement agency is amended, the amended price shall be displayed.
4. The Customer shall not be able to transfer items obtained in a Fee-Based Service to another Account or sell or transfer their Account.
5. If a minor uses the Services, the consent of a legal representative such as a parent is necessary for all use of the Services, including use of Fee-Based Services such as purchase of items and services (including consent to this Agreement and Individual Service Agreements).
6. There is a limit on the amount of Fee-Based Services that the Customer may use, as specified below. If Fee-Based Services are provided in excess of the maximum amount due to the Customer having selected or entered incorrect information regarding their age during the purchase process, Cygames will not be able to refund or accept returns for the amount in excess of the maximum amount:
Customers under the age of 16 years old: Up to 2,500 paid carats per month
Customers between the ages of 16 and 19 years old: Up to 5,000 paid carats per month
*“Paid carats” is the name of the Game Currency that can be purchased for money within the Services.
7. If a Customer who was a minor at the time of entering this Agreement or an Individual Service Agreement uses the Services after reaching adulthood, the Customer is deemed to have consented to all agreements relating to the use of the Services through the continued use of the Services.

Article 11 Prohibitions
1. The Customer shall not commit any of the following acts in relation to the Services, regardless of whether such actions occur inside or outside the Services. In addition, the Customer is prohibited from instructing, inciting, or coercing a third party to commit such acts:
(1) Any act in violation of this Agreement, any act that infringes upon the intellectual property rights or other legally protected rights of Cygames or any third party, criminal acts and other illegal acts, and any act that is likely to constitute or that promotes any of the preceding acts.
(2) Any act that causes discomfort to third parties, such as stalking, making offensive remarks, harassment, posting Content that arouses feelings of disgust, etc.
(3) Posting information that contains nudity, pornography, excessive violence, or offensive content, or information that contains links to such content.
(4) Any act that induces or promotes suicide or drug abuse.
(5) Inducing or soliciting others to commit antisocial acts, or providing benefits to or cooperating with antisocial forces.
(6) Political or religious activities, or soliciting people to join political or religious organizations.
(7) Acquiring, disclosing, falsifying, or leaking (or committing acts that may result in the acquisition, disclosure, falsification, or leak of) information that can identify specific individuals (e.g., names, titles, telephone numbers, email addresses, addresses, location information, etc.), or the non-public information, trade secrets, or confidential information of companies, organizations, etc., without the permission of the rights holder or the person, company, or group to which the information relates.
(8) Claiming to be, hinting to be, or otherwise impersonating Cygames, an affiliate company or a related person of Cygames, or a third party; or otherwise registering or posting false information.
(9) Any act intended to make a profit without the permission of Cygames (including the act of soliciting transactions similar to pyramid schemes, etc.)
(10) The unauthorized acquisition of various Content provided by Cygames through the Services (including, but not limited to, Content provided in the Fee-Based Services; hereinafter referred to as “In-Service Content”) or any other rights or benefits available to users in the Services in whole or in part, whether for free or for consideration; or disposing of such contents and rights etc. by transferring them to a third party, etc. (other than in the manner approved by Cygames); or any act that promotes such acts.
(11) Trading Game Currency, Accounts, In-Service Content, etc. for profit with real-world money, goods, services, or other economic benefits (so-called “real-money trading”), as well as performing any preparatory acts, including inducing another to trade, making offers to trade, or accepting offers to trade.
(12) Soliciting or inviting, while within the Services, users to use other services (except as approved by Cygames)..
(13) Providing links with the intention of promoting an act that is prohibited under this paragraph with the knowledge that such act falls under any of the items listed in this paragraph.
(14) Disassembling, decompiling, or reverse engineering the Services; or any act that Cygames deems hinders or may hinder related data (including rights notices), servers, and network systems, such as operating, modifying, acquiring, distributing, publishing, damaging, removing, or gaining unauthorized access to related data (including rights notices), servers, and network systems.
(15) Replicating, transmitting, transferring, renting, translating, adapting, or altering the Services, or combining the Services with other software.
(16) Using, creating, distributing, or selling technical means such as external tools and bots, or modified devices, which are not provided by Cygames and that affect the Services; or any act of using these to manipulate the Services without the permission of Cygames.
(17) Intentionally inducing or utilizing malfunctions of the Services, or using the Services for purposes not intended by Cygames.
(18) Using the Account of another Customer, holding multiple Accounts, or sharing an Account between multiple people without the permission of Cygames; or transferring to a third party or allowing a third party to use an Account, In-Service Content, or part or all of the rights and benefits available to the Customer in the Services in exchange for cash or other assets without the permission of Cygames.
(19) Making unreasonable inquiries or requests to Cygames (e.g., unnecessarily repeating a question or similar questions).
(20) Facilitating the raising of a ranking of a user or the acquisition of prizes in the Services by intentionally disconnecting the network during online play or repeatedly losing to certain other users.
(21) Any other act that Cygames deems interferes with, hinders, or damages, or may interfere with, hinder, or damage Cygames’ operation of the Services or another Customer’s use of the Services.
2. Cygames shall reserve the right to take the following measures if Cygames has confirmed that the Customer has committed or is likely to commit an act that corresponds to a prohibited act, or if Cygames determines the Customer’s use of the Services are inappropriate, or if the Customer admits to committing a prohibited act:
(1) Request the Customer to stop the prohibited act and not repeat said act.
(2) Revoke items or similar things acquired by the Customer and take other punitive measures in the Services.
(3) Suspend the Customer’s use of the Services in whole or in part.
(4) Suspend or delete the Customer’s Account.
(5) Revoke the rights obtained through prohibited acts.
(6) Disclose inside and outside the Services the relevant facts of the prohibited acts, including making a report to the police or another public agency in the case that the prohibited act may constitute a criminal case, administrative case, or other case.
(7) Take other measures that Cygames deems to be necessary and appropriate.
3. Cygames shall reserve the right not to provide Cygames services, including the Services (including refusal to provide services and deletion of registered accounts for other services), to a Customer whose Account has been deleted under item (4) of the preceding paragraph. Cygames may store personal information etc. to the extent necessary to take such measures.

Article 12 Limitations of the Services
1. Cygames shall not bear responsibility in the event that the Services are unavailable temporarily or for an extended period, or the Services themselves are suspended or terminated, due to the following causes:
(1) Natural disaster such as an earthquake, tsunami, typhoon, thunder, heavy rain, flood, etc., or force majeure events such as war, terrorism, revolution, labor disputes, etc.;
(2) Temporary or large-scale maintenance of systems or other equipment necessary for the operation of the Services;
(3) Congestion on the network line or a problem with the network provider, etc.; or
(4) Other disruptions that affect the operation of the Services.
2. Cygames shall not bear responsibility for any damage incurred by the Customer due to the actions of third parties, such as unauthorized access to the Services, computer viruses, etc.
3. Cygames shall not bear responsibility for damages (including but not limited to indirect, incidental, special, or exemplary damages; damages for loss of business, loss of data, or lost profits; or damages for wrongful death/personal injury) incurred by the Customer in connection with the Services, including those resulting from the termination or modification of the provision of the Services by Cygames. And in any case, the maximum liability of Cygames for all damage, loss, and causes of action shall be the total amount paid by the Customer to Cygames in the preceding six (6) months.
4. Cygames does not guarantee the safety, legality, etc. of third-party websites that can be accessed via links from the Services, or of products and services provided by third parties in relation to the use of the Services. Cygames is not responsible for any problems, promises, guarantees, etc. between the Customer and advertisers of advertisements placed on the Services, or for any losses or damage incurred by the Customer as a result.
5. Cygames shall not bear responsibility for damage incurred as a result of the Customer applying alterations, modifications, technical characteristics, etc. to the hardware or software of any devices and then not being able to properly use the Services. In addition, Cygames shall not take any action in this situation, such as restoring the Customer’s use of the Services.
6. Cygames does not guarantee the permanence of the information that the Customer has registered for the Services and shall not bear responsibility for any damage incurred by the Customer due to the Customer personally losing or forgetting registered information. In addition, Cygames shall bear no obligation to take any action in this situation, such as restoring the Customer’s use of the Services. The same shall also apply in the event that the Customer loses any registered information due to unauthorized use, loss, theft, failure, or any other reason in regard to the device used for the Services.
7. Cygames shall bear no obligation to respond to or take any action in response to any inquiries, ideas for improvement, or other suggestions or feedback from the Customer pertaining to the Services, etc. Any such response or action shall be at Cygames’ own discretion.
8. Cygames shall bear no obligation to repair bugs etc. in the Services or to reform or improve the Services.
9. The Customer shall use the Services at the Customer’s own risk and discretion. Cygames’ services and the Content are provided “as is” and without any guarantee as to the accuracy, completeness, correctness, validity, applicability, utility, or availability of the Services, either express or implied. Cygames does not guarantee the availability or accessibility of the Services at any time or place chosen by the Customer, or compatibility of the Services with the Customer’s intended use or the device used by the Customer (including devices recommended or presented as recommended devices or recommended user environments within the Services).
10. Cygames does not guarantee that the registered information etc. from the Customer’s previous device will be transferred to the new device when the Customer replaces the device used to access the Services with a new device due to repair or model change, etc., except in cases where Cygames specifically specifies otherwise. The same shall also apply in the event the Customer has deleted the app or Account information from their device, and to the transfer of registered information etc. when using the Services again.
11. No communication of any kind between the Customer and Cygames constitutes a waiver of any limitations of liability hereunder or creates any additional warranty not expressly stated in this Agreement.
12. The contents stipulated in this article shall be effective to the maximum extent permitted by applicable law.

Article 13 Termination
1. If the Customer withdraws from the Services, all outstanding obligations owed by the Customer to Cygames at that time shall be fulfilled immediately by the Customer.
2. The Customer agrees that the Customer will lose any Content remaining at the time the Customer withdraws from the Services, such as Game Currency and Game Items, at the time of such withdrawal.
3. If Cygames terminates the Customer’s access to the Services and use of the Customer’s Account, Cygames will have no liability to the Customer for any time spent by the Customer or for any Game Currency or Game Items acquired by the Customer.
4. Cygames shall bear no obligation to retain any information (e.g., personal information) of a Customer who has withdrawn from the Services.
5. The provisions of the preceding four paragraphs shall also apply in the case that Cygames has taken measures to delete the Customer’s account as specified in Article 11(2), item (4).

Article 14 Indemnity
The Customer agrees to reimburse Cygames for all damages resulting from the violation of this Agreement. The Customer releases Cygames from any third-party claims, liabilities, damages, losses, costs, expenses, or fees (including reasonable attorneys’ fees and court costs) that third parties may incur as a result of or arising from the Customer’s violation of (i) this Agreement; (ii) any law or regulation; or (iii) a third party’s proprietary or intellectual property right.

Article 15 Prohibition on the Transfer of Rights and Obligations
You shall not resell or assign your rights, duties, or obligations under this Agreement, and any attempted assignment or delegation will be void and of no force or effect whatsoever. This Agreement may be automatically assigned by Cygames, in our sole discretion, to a third party, and such an assignment will inure to the benefit of our successors, assigns, and/or licensees. Without limiting the foregoing, we may sell, transfer, or otherwise share some or all of our assets with any parent company, subsidiary, joint venture, and any company under our common control, as well as with a potential acquirer, lender, or investor, including in connection with a merger, reorganization, or sale of assets, or in the event of bankruptcy.

Article 16 Validity of This Agreement
1. If any part of this Agreement or the Individual Service Agreement is or becomes invalid or unenforceable, the rest of this Agreement and the Individual Service Agreement shall continue to apply and be binding, and any invalid or unenforceable term will be substituted with a valid and enforceable term that reflects Cygames’ intent as closely as possible.
2. This Agreement and the Individual Service Agreement comprise the entire agreement between parties relating to the subject matter, and (except in the case of fraud or a fraudulent misrepresentation) supersedes all prior understandings of the parties relating to the subject matter of this Agreement and/or the Individual Service Agreement, whether those prior understandings were electronic, oral, or written, or whether established by custom, practice, policy, or precedent, between the parties.

Article 17 Force Majeure
Cygames is not and shall not be liable for any failure to perform its obligations hereunder due to external, unforeseeable, and irresistible circumstances, such as changes or problems caused by natural disasters, war, terrorism, riots, cyber attack, embargoes, acts of civil or military authorities, fire, floods, accidents, network infrastructure failures (including network infrastructure failures related to the platform on which the Services are provided), strikes, pandemics (including government requests relating to a pandemic), or shortages of transportation facilities, fuel, energy, labor, or materials.

Article 18 Governing Law and Jurisdiction
Before bringing a formal legal case, the Customer should contact Cygames’ customer support team. Most disputes can be resolved that way. This Agreement shall be governed in all respects by the laws of Japan. The Customer agrees that any claim or dispute the Customer may have against Cygames must be resolved exclusively by the Tokyo District Court in Japan. The UN Convention on Contracts for the International Sale of Goods (CISG) shall be excluded. The mandatory provisions of the region in which the user resides in shall remain unaffected by this choice of law.

For residents of the United States, the following shall apply in place of Article 18:
Please note, the arbitration provision set forth below requires you to arbitrate any claims you may have against us on an individual basis. ARBITRATION ON AN INDIVIDUAL BASIS MEANS THAT YOU WILL NOT HAVE, AND YOU WAIVE, THE RIGHT FOR A JUDGE OR JURY TO DECIDE YOUR CLAIMS, AND THAT YOU MAY NOT PROCEED IN A CLASS, CONSOLIDATED, OR REPRESENTATIVE CAPACITY.

New Jersey’s Truth-in-Consumer, Contract, Notice, and Warranty Act
Under the New Jersey Truth-in-Consumer Contract, Warranty, and Notice Act (“TCCWNA”), N.J.S.A., consumers may not be offered any written contract which includes any provision that violates any clearly established legal right of a consumer, or responsibility of a seller, as established by New Jersey or federal law. Further, under the TCCWNA, no consumer contract may state that any of its provisions are or may be void, unenforceable, or inapplicable in certain jurisdictions without specifying whether such provisions are or are not void, unenforceable, or inapplicable in New Jersey. As such, please note the following:
• The limitations of liability and waiver of damages in Article 12(3) are not applicable to New Jersey residents.
• The indemnification requirement in Article 14 is not applicable to New Jersey residents.
• The provisions limiting a Customer’s right to a return or refund in Articles 7(3), 7(6), and 9(3) are applicable to New Jersey residents.

Disputes and Agreement to Arbitrate
This Agreement is governed by the laws of Japan, without resort to its conflict of laws principles. You further agree that any disputes or claims not subject to the arbitration provision discussed below shall be resolved by Tokyo District Court and you agree and submit to the exercise of personal jurisdiction of such courts for the purpose of litigating any such claim or action.
If any provision of this Agreement is found to be invalid by any court having competent jurisdiction, the invalidity of such provision shall not affect the validity of the remaining provisions of this Agreement.
By using Cygames Services, you and Cygames agree that, if there is any controversy, claim, action, or dispute arising out of or related to your use of our Services, or the breach, enforcement, interpretation, or validity of this Agreement or any part of it (“Dispute”), both parties shall first try in good faith to settle such Dispute by providing written notice to the other party describing the facts and circumstances of the Dispute and allowing the receiving party 30 days in which to respond to or settle the Dispute.
Notice shall be sent:
(1) to Cygames through: the email “service_info@cygames.co.jp”, or
(2) to the customer at: the contact details provided separately by the customer.
Both you and Cygames agree that this dispute resolution procedure is a condition precedent that must be satisfied before initiating any litigation or filing any claim against the other party.
IF ANY DISPUTE CANNOT BE RESOLVED BY THE ABOVE DISPUTE RESOLUTION PROCEDURE, YOU AGREE THAT THE SOLE AND EXCLUSIVE JURISDICTION FOR SUCH DISPUTE WILL BE DECIDED BY BINDING ARBITRATION ON AN INDIVIDUAL BASIS. ARBITRATION ON AN INDIVIDUAL BASIS MEANS THAT YOU WILL NOT HAVE, AND YOU WAIVE, THE RIGHT FOR A JUDGE OR JURY TO DECIDE YOUR CLAIMS, AND THAT YOU MAY NOT PROCEED IN A CLASS, CONSOLIDATED, OR REPRESENTATIVE CAPACITY. Other rights that you and we would have in court will not be available or will be more limited in arbitration, including discovery and appeal rights. All such Disputes shall be exclusively submitted to JAMS (www.jamsadr.com) for binding arbitration under its rules and before one arbitrator to be mutually agreed upon by both parties. The JAMS rules that will apply are the rules in effect at the time the arbitration takes place.
The arbitrator, and not any federal, state, or local court or agency, shall have exclusive authority to resolve any dispute arising under or relating to the interpretation, applicability, enforceability, or formation of this Agreement, including any claim that all or any part of this Agreement is void or voidable.
The parties acknowledge that this Agreement evidences a transaction involving interstate commerce. Notwithstanding the provision in the preceding paragraph with respect to applicable substantive law, any arbitration conducted pursuant to the terms of this Agreement shall be governed by the Federal Arbitration Act (9 U.S.C. §§ 1-16).

Article 19 No Waiver
Our failure to act with respect to a breach by you or others does not waive our right to act with respect to a subsequent or similar breach or breaches. If Cygames does not exercise or enforce any legal right or remedy which is contained in this Agreement or the Individual Service Agreement (or which Cygames has the benefit of under any applicable law or regulation), such action or inaction shall not be taken to be a formal waiver of Cygames’ rights, and all such rights or remedies shall still be available to Cygames. Any waiver must be in writing and signed by both parties to be legally binding.

Article 20 Consumer’s Rights
For residents of California, the following shall apply:
Under California Civil Code Section 1789.3, residents of California are entitled to the following specific consumer rights notice: The Complaint Assistance Unit of the Division of Consumer Services of the California Department of Consumer Affairs may be contacted in writing at 400 R Street, Suite 1080, Sacramento, California, 95814, or by telephone at (916) 445-1254 or (800) 952-5210.

For residents of South Korea, the following shall apply:
Refund of Fee-Based Services
1. Notwithstanding Article 7(3), the Customer may cancel any Fee-Based Service and demand a refund within seven (7) days from the purchase date or the start date of the Fee-Based Service; provided, however, the Customer will not be entitled to a refund in any of the following cases:
1. the product is lost or damaged due to a cause attributable to the Customer;
2. the Customer has used or partially consumed the product;
3. the resale of the product is difficult due to the passage of time;
4. the packaging of a reproducible product is damaged; or
5. any other reason stipulated by law to ensure the secure transaction of the product.
In the event that the Customer may not cancel a Fee-Based Service for reasons 2 through 4 above, Cygames shall take measures to ensure that the Customer is not blocked from exercising the cancellation right by clearly indicating such fact on the product’s packaging or another location that is easily noticeable by the Customer, or providing a test sample of the product to the Customer.
2. Notwithstanding the provision above, if the contents of the Fee-Based Service are different from the labeling, advertisement, or terms of the agreement, the Customer may cancel a Fee-Based Service within three (3) months of the purchase date or start date of the Fee-Based Service, or thirty (30) days from the date on which the Customer realizes or could have realized a discrepancy.
3. In the event the Customer cancels any Fee-Based Service, Cygames shall immediately withdraw/delete the Fee-Based Service and refund the payment for the Fee-Based Service made by the Customer within three (3) business days of withdrawal/deletion; provided, however, if any of the cancelled products or Services have been already used or consumed in part by the Customer, Cygames may only refund the amount remaining after deducting the value of the Fee-Based Service that has already been used or consumed by the Customer.

For residents of France, Germany, Spain, Italy, and the United Kingdom, the following shall apply:
Right to Withdrawal and Instructions for the Right to Withdrawal
You have the right to withdraw from any purchase within 14 days without giving any reason.
The withdrawal period will expire after 14 days from the day you enter the contract for any purchase.
To exercise the right to withdrawal, you must inform us of your decision to withdraw from the contract with a clear statement (e.g., a letter sent by mail, fax, or email). You may use the Model Withdrawal Form below, but it is not obligatory. We will confirm the receipt of your withdrawal without undue delay on a durable medium.
To meet the withdrawal deadline, it is required of you to send your request concerning the exercise of your right to withdrawal before the withdrawal period has expired.

Effects of Withdrawal
If you withdraw from any purchase, you will still need to pay for any services provided up to the time you withdraw but we will reimburse you for the balance of all payments we have received from you for the purchase after deducting such amount.

We will make the reimbursement without undue delay and no later than 14 days after the day on which we are informed about your decision to withdraw from this contract.
We will make the reimbursement using the same means of payment as you used for the initial transaction, unless expressly agreed otherwise; in any event, you will not incur any fees as a result of the reimbursement.

Early Expiration of the Right to Withdrawal
In relation to purchase of Game Items, the right to withdrawal expires if you commence using the Game Items after you have expressly consented to such commencement prior to the expiry of the withdrawal period, and you have acknowledged that by this consent you lose your right to withdraw.

Model Withdrawal Form
(If you want to withdraw from the contract, please complete and return this form.)
- To Cygames, Inc.:
I hereby give notice that I withdraw from my contract [for the supply of the following digital content/for the provision of the following service]:
- Ordered on:
- Name of Customer(s):
- Address of Customer(s):
- Signature of Customer(s) (only if this form is notified on paper):
- Date:

The following shall also apply for residents of France, Germany, Spain, Italy, and the United Kingdom:
• The limitations of liability and waiver of damages in Article 12(3) are not applicable.
• Notwithstanding Article 12(9) and subject to certain exceptions,
(i) under applicable consumer law, the Customer may be entitled to a refund if Services are not as described or of satisfactory quality; and
(ii) under applicable consumer law, the Customer may be entitled to a repair of the Device or compensation if the Customer can show the fault of Services has damaged the Device and Cygames did not use reasonable care and skill.
• Article 18 shall not prohibit the Customer from bringing a claim or dispute against Cygames in the country of the Customer’s habitual residence.




Privacy Policy

Original Effective Date: June 24, 2024
Last Updated: June 24, 2025

Cygames, Inc., as well as its subsidiaries and affiliated entities (“Cygames,” “we,” or “us”), takes the protection of your personal data very seriously. The following privacy policy (the “Privacy Policy”) will provide you with information about personal data that we collect and how it is processed and used.
PLEASE READ THIS PRIVACY POLICY CAREFULLY BECAUSE, BY USING THE SERVICES, YOU CONSENT TO THE TERMS AND CONDITIONS OF THIS PRIVACY POLICY AND TO OUR PROCESSING OF PERSONAL DATA FOR THE PURPOSES STATED BELOW. IF YOU DO NOT AGREE WITH THE TERMS AND CONDITIONS OF THIS PRIVACY POLICY, PLEASE DO NOT USE THE SERVICES.
In order to ensure the secure processing of your personal data, we have implemented all safeguards required by law.

1. Scope of This Privacy Policy
This Privacy Policy applies only to services related to “Umamusume: Pretty Derby” controlled by Cygames (the “Services”).

2. Personal Data Collected (Categories and Sources of Personal Data)
We may collect the following personal data:
- Your name, address, email address, and social media accounts, if you provide them to us
- Whether you are currently using the Services or you are still considering using the Services, and if you are currently using the Services, the version of the Services you are using
- Your Internet Protocol (IP) address, cookies, and other online identifiers
- Your behavioral data on the internet including browsing history and information on your interaction with a website
- Your date of birth and/or telephone number if necessary for us to provide the Services
- Device information
- Countries/areas where you live
- Log information
- Information about your accounts associated with the Services’ game platform
- Contents of your inquiries, including problems you experience, if you contact us to make inquiries
- Inferences drawn from personal data to create your profile reflecting a person’s preferences or behavior and the like
- Other personal data required to provide the Services (you will be notified separately of the category of data if required under applicable data protection regulations)
Personal data is collected directly from you, collected indirectly from service providers and platforms and other third parties, or inferred from collected data.

3. Cookies
We use cookies in the Services.
Cookies are small text files that websites send to your device for the purpose of keeping records. Cookies identify your device and, typically, your web browser. Some cookies are necessary to operate our website (e.g., establishing sessions), while other cookies provide enhanced functionality, gather analytical data to improve performance, enable us or our AdTech partners to deliver personalized advertisements by tracking you across the Internet, or enable sharing via social media.
You can choose whether to allow us or third parties (e.g., our analytics, AdTech, and social media partners) to set cookies which are not strictly necessary for the functioning of our website via the cookie banner and settings provided on our website.
Please be aware that when we talk about “cookies,” this term also includes other technologies (such as pixel tags and web beacons) which have the same purpose as the cookies described in this Privacy Policy.
First-party cookies are put on your device directly by the website you are visiting.
Third-party cookies are placed on your device, not by the website you are visiting, but by a third party such as an advertiser or a provider of analytics software.
If you would like to know the details of our use of cookies or change settings for the use of cookies, please refer to our Cookies Settings.
You may also set most browsers to notify you if you receive a cookie, or you may choose to block cookies with your browser. If you do so, you may not be able to take advantage of the personalized features enjoyed by other users of the Services.
Cookies Settings

4. Use of Tracking and Similar Tools Provided by Third Parties
We engage in targeted advertising and use advertisers to serve advertisements on and off our Services. These third parties use cookies and similar technologies to collect or receive information from our Services and elsewhere on the Internet and use that information to provide you with targeted ads. You may remove yourself from the targeted advertising of companies within the Network Advertising Initiative by opting out via their official website (https://optout.networkadvertising.org/?c=1), or of companies participating in the Digital Advertising Alliance program by opting out here: https://optout.aboutads.info/?c=2&lang=EN. You can also use the Digital Advertising Alliance mobile app, available on the App Store, Google Play, and Amazon’s Appstore, to control interest-based advertising on apps on your mobile device. Mobile app guidance is available here: https://digitaladvertisingalliance.org/app.

Additionally, we use Google Analytics. Google Analytics is a web analytics service provided by Google LLC (“Google”) which collects anonymous statistical and analytical information about how our users use the Services. For example, Google gathers and aggregates data on page views and clicks within the Services. These analytics are not used to track your journey to other websites or to identify you. The information generated by the Google Analytics cookies about your use of the Services (including your IP address) will be transmitted to and stored by Google on servers in the United States.
You can find a more detailed account of Google’s privacy policy here:
https://policies.google.com/privacy?hl=en.
Instructions on how to opt out of Google Analytics using a specific plug-in are available at the following link: https://tools.google.com/dlpage/gaoptout. Note that this opt-out is specific to Google activities.

We use Google Analytics for Firebase and Firebase Crashlytics. Google Analytics for Firebase is a web analytics service provided by Google which collects anonymous statistical and analytical information about how our users use the Services. Firebase Crashlytics is provided by Google and collects information about the device on which you are using the Service, information about crash conditions, and other information. The collection and use of device and other information is governed by the Firebase Policy, available at the following link: https://firebase.google.com/support/privacy.

We also use Adjust, an advertisement tracking tool for smartphone apps provided by Adjust GmbH. This tool makes it possible to measure and analyze the effectiveness of smartphone advertising. Adjust collects personal information as described below and aggregated information (information about groups or categories of persons, which does not identify and cannot reasonably be used to identify an individual person). Adjust uses IDFA, GPS, ADID, and log files to help the app analyze how users use the app. The information held in log files includes the user's IP address, internet service provider, and date/time stamp, as well as user activity. Furthermore, Adjust utilizes a variety of tracking methods to collect information.
You can find a more detailed account of Adjust’s privacy policy here: https://www.adjust.com/terms/privacy-policy/

We use Datadog, which is provided by Datadog, Inc., in conjunction with the use of the Services. Datadog is a service that acquires anonymized system log information issued in conjunction with the use of the Services and measures your activity history, etc.
You can find a more detailed account of Datadog’s privacy policy here:
https://www.datadoghq.com/legal/privacy/

5. Your Choice Regarding Online Tracking
Our online services are not designed to respond to “Do Not Track” requests from browsers. However, you may communicate your privacy preference via the Global Privacy Control opt-out preference signal. To install Global Privacy Control, which is a device-specific browser or browser extension, please visit their official website (https://globalprivacycontrol.org/).

6. Use of Personal Data
We may process your personal data for the purposes described below:
- To deliver content such as games, video, and music; and provide related services
- To develop services; compile statistics, analysis, and questionnaires; and conduct other marketing activities intended to improve services
- To contact and communicate with you to respond to your inquiries and complaints
- To provide you with special offers, campaign information, updated information and other new services, newsletters, and any other information from Cygames or other third parties
- To complete a transaction or service requested by you
- To fulfill marketing or promotional purposes
- To allow you to share the link to our contents on social media
- To improve the Services
- To create and publish content that is the most relevant to you
- To notify you about a change to this Privacy Policy or the Terms of Service, if necessary
- To resolve disputes with you
- For other purposes of use as separately disclosed
Provision of your personal data is mandatory in some cases, such as for a statutory reason, contractual requirement, or a requirement necessary to enter into a contract. We may be unable to provide our service to you if you don’t provide such personal data.

7. Disclosure to Third Parties
We may share or disclose your personal data specified in Article 2 (Personal Data Collected (Categories and Sources of Personal Data)) to the extent necessary with or to third parties for the following purposes:
- To provide the Services to you, we may disclose your personal data to service providers. Service providers are agents or independent contractors which provide the Services on behalf of us (including those involved in the organization of e-sports competitions), help us develop and maintain the Services, and provide other administrative services to us.
- In addition, to store and manage data on servers, we may use Amazon Web Services, Inc. (“AWS”), Zendesk, Inc., Akamai Technologies, Inc., and other cloud service providers to process your personal data. We may also disclose your personal data to service providers who provide services to evaluate the effects of advertisement. When engaging service providers, we enter into agreements for the protection of personal data with the delegated parties and request consent to the terms and agreements thereof so as to safely manage personal data.
- Data collection by social media providers and video distribution platforms: Buttons through which you can share our content on social media or video links to video distribution platforms may be embedded in our websites. In this case, the social media providers and video distribution platforms may obtain your personal data.
- To comply with laws and regulations, we may share personal data when necessary or in the good-faith belief that such action is necessary under the requirements of a law or regulation, a legally binding court order, or a governmental order from an investigative agency or competent regulatory authority that is issued with due process, to protect and defend our rights or property or both, or to act in urgent circumstances when it is necessary to protect the life, body, or property of a person, and the consent of the identified individual is difficult to obtain.
- We may share or disclose personal data with or to third parties as part of any corporate reorganization process including, but not limited to, mergers, acquisitions, and sales of all or substantially all of our assets.

8. Security
No data transmissions over the Internet can be guaranteed to be 100% secure. Consequently, we cannot ensure or warrant the security of any information that you transmit to us, and you understand that any information that you transfer to Cygames is transmitted at your own risk. Cygames specifies rules for the protection of personal data, and incorporates appropriate administrative, technical, organizational, and physical security measures that are required under applicable regulations. We use firewalls to protect your information from unauthorized access, disclosure, alteration, or destruction. However, please note that this is not a guarantee that such information may not be accessed, disclosed, altered, or destroyed by breach of said firewalls and secure server software.
If we learn of any security systems breach, we may attempt to notify you electronically so that you can take the appropriate protective measures. By using the Services or providing personal data to us, you agree that we can communicate with you electronically regarding security, privacy, and administrative issues relating to your use of the Services. We may post a notice on our Services if a security breach occurs. We may also send an email to you at the email address you have provided to us.

9. Rights of Data Subjects
We respect the rights you have under the personal data protection regulations applicable to you. You may demand the disclosure of, correction of, addition to, or deletion in the content of; stoppage or elimination of usage of; or stoppage of third-party provision of your personal data or disclosure of records for the provision of your personal data to third parties pursuant to the Act on the Protection of Personal Information of Japan. In addition to these rights, other rights may be granted to you under the applicable personal data protection regulations of other countries, as may be applicable. For example, in accordance with personal data protection regulations of an applicable country, you may be granted the following rights, and if the conditions prescribed by such personal data protection regulations are satisfied, we will comply with your exercise of such rights.
- Access to your personal data:
The right to obtain confirmation from us on whether your personal data has been or is being processed, and if it has been or is being processed, the right to access the relevant personal data and specific related information
- Correction of your personal data:
The right to modify incorrect personal data regarding you without unreasonable delay and the right to complete your personal data that is incomplete
- Deletion of your personal data:
The right to delete personal data related to you without unreasonable delay
- Restriction on the processing of your personal data:
The right to restrict the processing of your personal data
- Objecting to the processing of your personal data:
The right to file an objection to the processing of your personal data if it affects your rights
- Withdrawal of consent:
The right to withdraw your consent on which we rely to process your personal data (However, your withdrawal of consent does not affect the lawfulness of processing conducted based on your consent before its withdrawal.)
- Data portability:
The right to receive your personal data in a structured and generally machine-readable form, and the right to transfer the data to third parties without interference from us
If you wish to exercise any of the foregoing rights, please inquire with us using the contact information stated in Article 17 (Contacting Us). In order to confirm your identity, it may be necessary for us to ask for specific information from you. In addition, in order to streamline correspondences from us, we may contact you to ask for additional information in connection with your inquiry.
Further, you may directly file a complaint with the relevant supervisory agency in connection with our processing of your personal data.

10. Accounts Information
Access to your account and our Services is sometimes only possible through the use of an individual user ID and password. To protect the confidentiality of personal data, you must keep your password confidential and not disclose it to any other person. Please note that we will never ask you to disclose your password in an unsolicited phone call or email. CYGAMES IS NOT RESPONSIBLE FOR ACTIONS TAKEN REGARDING YOUR ACCOUNT WHILE A USER IS LOGGED IN USING YOUR USER ID AND PASSWORD.

11. Retention Period
We retain personal data for as long as necessary to fulfill the purposes for which we collected it, including for the purposes of satisfying any legal, accounting, or reporting requirements, to establish or defend legal claims, or for compliance and protection purposes.
To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorized use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.

12. International Transfer of Information
Personal data which you choose to provide to us will be stored in Japan. We may transfer (by any means including sending or allowing access) that information to countries or areas outside of the country or area where you live in accordance with applicable laws and regulations. At this moment, we transfer personal data to Japan and the United States. In addition, our service providers also use cloud servers provided by AWS, and your personal data may be processed in any of the regions or edge locations stated in the page below:
https://aws.amazon.com/about-aws/global-infrastructure/regions_az/
Such personal data may be processed by such parties for the term necessary to fulfill purposes specified in Article 7 (Disclosure to Third Parties).

13. Chat Rooms, Forums, and Other Public Posting Areas
Please note that any information you include in a message you post to any chat room, forum, or other public posting area is available to anyone with Internet access. If, for example, you do not want people to know your email address, do not include it in any message you post publicly. PLEASE BE EXTREMELY CAREFUL WHEN DISCLOSING ANY INFORMATION IN CHAT ROOMS, FORUMS, AND OTHER PUBLIC POSTING AREAS. WE ARE NOT RESPONSIBLE FOR THE USE BY OTHERS OF THE INFORMATION THAT YOU DISCLOSE IN CHAT ROOMS, FORUMS, AND OTHER PUBLIC POSTING AREAS.

14. Third-Party Services
This Privacy Policy applies solely to information collected on the Services. The Services may contain links to other web services. We are not responsible for the privacy practices or the contents of these other web services.

15. Changes to This Privacy Policy
We reserve the right to change this Privacy Policy from time to time. When we do, we will also revise the “last updated” date at the top of this Privacy Policy. For some changes to this Privacy Policy we may attempt to obtain your consent before implementing the change by placing a notice on the Services. The continued use of the Services following such notice will be viewed as consent to such changes unless otherwise specified.

16. Our Policy Regarding Children
If we learn that we have collected personal data from a child under the age of 13 without legal grounds, we will delete the information as quickly as possible. If you believe that we may have any information from or about a child under the age of 13 without legal grounds, please contact us by email at service_info@cygames.co.jp.

17. Contacting Us
If you have any questions about this Privacy Policy, our privacy practices, or regarding information on or the correction, blockage, or deletion of data, please contact us by email at service_info@cygames.co.jp.


Addendum for Residents of the European Economic Area and the UK
For residents of the European Economic Area and the UK, the following shall also apply.

1. Legal Basis for Processing
We will always process your personal data based on one of the legal bases provided for in the GDPR (Articles 6 and 7). We process your personal data for the purposes stipulated in the following paragraphs based on the legal grounds listed below.
(a) Performance of a contract (Article 6(1)(b) of the GDPR)
We process your personal data because it is necessary for the performance of a contract or in order to take steps at the request of the data subject (that is, you) prior to entering into a contract (Article 6(1)(b) of the GDPR).
(b) Legitimate interests (Article 6(1)(f) of the GDPR)
We process your personal data because it is necessary to do so in order to pursue our legitimate interests (Article 6(1)(f) of the GDPR):
(c) Consent (Article 6(1)(a) of the GDPR)
We process your personal data based on your consent (Article 6(1)(a) of the GDPR):

The above legal grounds shall include the following purposes:
- To deliver content such as games, video, and music; and provide related services
- To contact and communicate with you to respond to your inquiries and complaints
- To complete a transaction or service requested by you
- To notify you about a change to this Privacy Policy or the Terms of Service, if necessary
- To develop services; compile statistics, analysis, and questionnaires; and conduct other marketing activities intended to improve services
- To fulfill marketing or promotional purposes
- To improve the Services
- To create and publish content that is the most relevant to you
- To allow you to share the link to our contents on social media
- To process strictly necessary cookies
- To resolve disputes with you
- To process cookies (except for strictly necessary cookies) as well as your personal data obtained through such cookies
- To provide you with special offers, updated information and other new services and other services, newsletters, and any other information from Cygames or other third parties

2. Overseas Transfer of Personal Data
If an adequacy decision is made with respect to a third country, we share or disclose your personal data to a person in that third country on the basis of the adequacy decision (Article 45 of the GDPR). For transfer to Japan, we will transfer your personal data based on the adequacy decision for Japan (https://eur-lex.europa.eu/legal-content/EN/TXT/PDF/?uri=CELEX:32019D0419&from=EN).
If no adequacy decision is made with respect to a third country, we share or disclose your personal data to a person in that third country by executing with the transferee the standard data protection clauses (https://ec.europa.eu/info/law/law-topic/data-protection/international-dimension-data-protection/standard-contractual-clauses-scc_en) (Article 46(2)(c) and (5) of the GDPR) approved by the European Commission.

3. Your Rights
You have the following rights:
- Obtaining information regarding data processing: You have the right to obtain from us all necessary information regarding our processing of data concerning you (Articles 13 and 14 of the GDPR).
- Access to personal information: You have the right to obtain confirmation from us as to whether or not personal information concerning you is being processed, and, where that is the case, to access personal information and certain information (Article 15 of the GDPR).
- Rectification and erasure of personal information: You have the right to have us rectify inaccurate personal information concerning you without undue delay and have incomplete personal information completed by us (Article 16 of the GDPR). You also have the right to have us erase personal information concerning you without undue delay when certain conditions are met (Article 17 of the GDPR).
- Restricting processing of personal information: You have the right to restrict our processing of personal information concerning you when certain conditions are met (Article 18 of the GDPR).
- Objection to processing of personal information: You have the right to object to our processing of personal information concerning you when certain conditions are met (Article 21 of the GDPR).
- Personal information portability: You have the right to receive personal information concerning you in a structured, commonly used, and machine-readable format, and to transmit those data to another controller without hindrance from us, when certain conditions are met (Article 20 of the GDPR).
- Right to withdraw your consent: You have the right to withdraw your consent at any time by the means separately specified at the time we obtain your consent. However, your withdrawal of consent does not affect the lawfulness of processing conducted based on your consent before its withdrawal (Article 7 of the GDPR).
- Freedom from automated decision-making: You have the right to not be subject to automated (no human involvement) decision-making which produces legal effects or significant effects on you, when certain conditions are met (Article 22 of the GDPR). In addition, regarding our processing of your personal information, if you live in the EEA, you may lodge a complaint directly with the relevant supervisory authority (see here for a list: https://edpb.europa.eu/about-edpb/about-edpb/members_en), or if you live in the United Kingdom, you may lodge a complaint directly with Information Commissioner’s Office.

4. EEA and UK Representatives

For data protection matters, we have appointed Bird & Bird GDPR Representative Services SRL as our representative in the EEA and Bird & Bird GDPR Representative Services UK as our representative in the UK.
You can contact them by email at the addresses listed below. Your message will be forwarded to appropriate members of their data privacy teams.

EEA Residents: EUrepresentative.Cygames@twobirds.com
UK Residents: UKrepresentative.Cygames@twobirds.com


Addendum for Residents of California
For residents of California, the following shall also apply.
1. Notice at Collection
This addendum contains disclosures required by the California Consumer Privacy Act as amended by the California Privacy Rights Act (“CCPA”). We may collect or process various categories of personal data described under the CCPA (“California Personal Data”). Information on the categories of California Personal Data collected and/or whether we sell or share California Personal Data is contained in Sections 2 (Categories of California Personal Data Collected by Us) and 5 (Recipients of California Personal Data) below. Information on the length of time the business intends to retain California Personal Data is contained in Section 6 (Retention Period) below.
Information on your rights regarding your California Personal Data is contained in Section 8 (Your Rights concerning California Personal Data) below.

2. Categories of California Personal Data Collected by Us
We have collected the following categories of California Personal Data from and about you in the preceding 12 months:
(a) Identifiers including names, unique personal identifiers, cookies, online identifiers, Internet Protocol addresses, email addresses, account names and passwords, postal addresses, telephone numbers, dates of birth, or other similar identifiers
(b) Personal data categories contained in customer records including names, bank account numbers, credit card numbers, debit card numbers, or any other payment and financial information
(c) Commercial information including records of services purchased, obtained, or considered; or other purchase or consumption histories or tendencies
(d) Internet or other similar network activities including browsing history, device information, and information on your interaction with a website
(e) Geolocation data which may be broad location information, but not precise geolocation information
(f) Inferences drawn from personal data to create your profile reflecting a person’s preferences or behavior and the like
(g) Sensitive personal information: log-in ID and password for your Cygames account

3. Categories of Sources of California Personal Data
In the past 12 months we have collected the California Personal Data specified in Section 2 of this Addendum from the categories of sources as specified in Article 2 (Personal Data Collected (Categories and Sources of Personal Data)) of the Privacy Policy.

4. Use of California Personal Data
We use California Personal Data for the purposes set forth in Article 6 (Use of Personal Data) of the Privacy Policy.

Our business purposes for the use of California Personal Data include:
i. auditing our interactions with you;
ii. ensuring security and integrity;
iii. debugging;
iv. short-term, transient uses, including non-personalized advertising;
v. enabling service providers to perform the Services on our behalf;
vi. advertising and marketing the services, except for cross-context behavioral advertising;
vii. internal research for technological improvement;
viii. verifying or maintaining the quality or safety of services or devices that are owned, manufactured, manufactured for, or controlled by us, and for improving, upgrading, or enhancing services or devices that are owned, manufactured, manufactured for, or controlled by us; and
ix. other operational purposes, purposes for which we provide additional notice, purposes disclosed elsewhere in this Privacy Policy, or purposes compatible with the context in which the personal information was collected.

Our commercial purposes for the use of California Personal Data include advancing commercial or economic interests, such as by inducing consumers to buy or subscribe to goods or services, or enabling or effecting, directly or indirectly, a commercial transaction including distributing targeted advertising.

5. Recipients of California Personal Data
We have not disclosed California Personal Data to anyone other than service providers under the CCPA. We have sold/shared the following categories of California Personal Data to the following categories of recipients for the business and commercial purposes listed in Section 4 (Use of California Personal Data) above in the preceding 12 months, namely for purposes of distributing targeted advertising.
Category of California Personal Data and category of third parties sold to/shared with

Category: Identifiers
Sold to/shared with:
Third-party Internet advertising networks that provide you with
relevant Internet-based advertisements across the Internet

Category: Personal data contained in customer records
Sold to/shared with:
N/A

Category: Commercial information
Sold to/shared with:
Third-party Internet advertising networks that provide you with
relevant Internet-based advertisements across the Internet

Category: Geolocation data
Sold to/shared with:
Third-party Internet advertising networks that provide you with
relevant Internet-based advertisements across the Internet

Category: Internet and other network activity
Sold to/shared with:
Third-party Internet advertising networks that provide you with
relevant Internet-based advertisements across the Internet

Category: Inferences Drawn from Personal Data
Sold to/shared with:
Third-party Internet advertising networks that provide you with
relevant Internet-based advertisements across the Internet

6. Retention Period
We retain California Personal Data for the period explained in Article 11 (Retention Period) of this Privacy Policy.

7. Sensitive Personal Information
We do not use or disclose sensitive personal information for any purpose beyond those for which it was provided.

8. Your Rights concerning California Personal Data
California residents have certain rights with respect to California Personal Data we collect. If you are a California resident, you may exercise the following rights regarding your California Personal Data, subject to certain exceptions and limitations:
● The right to know the categories and specific pieces of California Personal Data we collect, use, disclose, sell, and share about you; the categories of sources from which we collected your California Personal Data; our purposes for collecting, selling, or sharing your California Personal Data; the categories of your California Personal Data that we have either sold or disclosed for a business purpose; and the categories of third parties with which we have shared California Personal Data.
● The right to request that we delete the California Personal Data we have collected from you or maintain about you.
● The right to correct inaccurate California Personal Data we maintain about you.
● The right to opt out of our sale(s) and sharing of your California Personal Data. We obtain opt-in consent before selling or sharing any California Personal Data. Cygames may sell or share California Personal Data of children under the age of 16 years, but Cygames obtains opt-in consent.
● The right to opt out of profiling, except under certain exceptions under local law.
● The right to receive your California Personal Data in a structured and generally machine-readable form, and the right to transfer the data to third parties without interference from us.
● The right not to receive discriminatory treatment for the exercise of privacy rights.
● You, as a California resident, may ask us to request a list of the categories of personal data (if any) we disclosed to third parties for their own direct marketing purposes in the preceding calendar year and the names and addresses of those third parties. You may also ask us to refrain from sharing your personal data with third parties for their marketing purposes.

To exercise the above rights except for the right to opt out of our sale(s) or sharing of your California Personal Data, please contact us using the information in Article 17 (Contacting Us) of the Privacy Policy and submit the required verification information described below.
To opt out of sales or the sharing of your California Personal Data, please select and implement either of the following measures:
● Visit the Your Privacy Choices page available here.
● We support the Global Privacy Control opt-out preference signal, and interpret such signals as requests for opt-out of sales and the sharing of your California Personal Data. To install Global Privacy Control, please visit their official website (https://globalprivacycontrol.org/).

Verification procedures and necessary information: We may request that you provide additional information to verify your identity or to correctly understand, evaluate, and respond to your request, but you are not required to create an account with us in order to have it fulfilled. We ask you to provide specific California Personal Data for our records and reference. We will require you to provide, at a minimum, your name and email address.

Authorized agent: If you are a California resident, you may designate an authorized agent to submit requests on your behalf by designating such an agent in writing. We may require the agent to provide us with proof that you have authorized the agent to make requests on your behalf prior to accepting requests from the agent.