TOBON GAME — Privacy Policy
Privacy Policy
TOBON GAME ("we", "us", or "our studio") considers the protection of your personal information an important responsibility and handles personal information in compliance with the applicable laws of each country and region. This Policy explains how personal information is handled on the website we operate, https://tobongame.com (the "Website"), and in the games we distribute (the "Games"; together with the Website, the "Services").
1. Business Information
Trade name: TOBON GAME
Address: Shibuya Dogenzaka Tokyu Building 2F-C, 1-10-8 Dogenzaka, Shibuya-ku, Tokyo 150-0043, Japan
Contact: tobongame@gmail.com
Person responsible for personal information protection: Our representative
2. Personal Information We Collect
2.1 Information collected through the Website
• Access log information (IP address, browser type and version, operating system, referrer, date and time of access, pages viewed, etc.)
• Identifiers such as cookies and local storage (the Website may use localStorage to retain display settings. We do not use cookies for advertising purposes.)
• Information you provide when contacting us (your name, email address, inquiry, and any other information you voluntarily provide)
2.2 Information collected through the Games
The Games are provided through the following distribution platforms. For information collected or processed through these platforms, the privacy policy of the respective company takes precedence.
• Steam (Valve Corporation, United States): purchase history, playtime, achievements unlocked, use of friend features, Steam Cloud saves, etc.
• Google Play (Google LLC, United States): purchase history, installation status, device information, use of Google Play Games, etc.
• Apple App Store (Apple Inc., United States): purchase history, use of Game Center, device information, etc.
• Information our studio collects within the Games: save data, settings, error logs, etc., to the extent necessary for the Games to function. These are processed as statistical information that does not include personally identifying information.
3. Purposes of Use
We use the information we collect only for the following purposes.
• Responding to inquiries
• Providing, operating, and improving the Services
• Fixing bugs, improving features, and enhancing quality
• Statistical analysis of usage
• Sending important notices (release information, updates, policy revisions, etc.)
• Responding as required by law
4. Disclosure to Third Parties and Service Providers
We do not provide personal information to third parties without your consent, except as provided by law.
To carry out our operations, we may entrust the handling of information to the following companies. We appropriately supervise these service providers.
• Website hosting: Xserver Inc. (Japan)
• Email forwarding and receipt: Xserver Inc. (Japan), Google LLC (Gmail, United States)
• Game distribution platforms: Valve Corporation (Steam, United States), Google LLC (Google Play, United States), Apple Inc. (App Store, United States)
5. Transfers of Personal Data Overseas
The game distribution platforms (Steam, Google Play, and Apple App Store) are all based in the United States. Personal information collected through these services is processed on the respective companies' servers in the United States. Each company has implemented Standard Contractual Clauses (SCCs) or other appropriate safeguards to comply with the GDPR and UK GDPR.
For transfers to other service providers based in the United States (such as Google LLC), we also select providers that have implemented similar measures.
6. Matters under Japan's Act on the Protection of Personal Information (APPI)
Our studio complies with the Act on the Protection of Personal Information.
Name of the personal information handling business operator: TOBON GAME
Contact for inquiries: tobongame@gmail.com
To request disclosure, correction, addition, deletion, suspension of use, or suspension of disclosure to third parties of retained personal data, please contact us at the address above. We will verify your identity and respond within a reasonable period.
We appropriately create and retain records of disclosures to third parties and acquisitions from third parties in accordance with the law. The provision of personal data to third parties in foreign countries is described in Section 5 of this Policy.
7. Matters under the EU/EEA and UK Data Protection Regulations (GDPR / UK GDPR)
When we handle the personal data of residents of the EU/EEA or the United Kingdom, our studio is responsible as the Controller and complies with the GDPR / UK GDPR.
Legal bases: We process data on the basis of performance of a contract (GDPR Article 6(1)(b)), legitimate interests (Article 6(1)(f)), or consent (Article 6(1)(a)).
Data subject rights: You have the rights of access, rectification, erasure, restriction of processing, data portability, objection, and withdrawal of consent. To exercise these rights, please contact tobongame@gmail.com.
Data retention period: We retain data for the period necessary to achieve the purposes of use or for the period required by law.
Complaints to supervisory authorities: You have the right to lodge a complaint with the supervisory authority in your location.
International transfers: Please see Section 5 of this Policy.
8. Matters under California Consumer Privacy Laws (CCPA / CPRA)
Residents of California have the following rights under the CCPA and CPRA.
• Right to know: The right to know the categories and specific pieces of personal information that we collect, use, and disclose
• Right to deletion: The right to request deletion of personal information we hold
• Right to correction: The right to request correction of inaccurate personal information
• Opt out of sale or sharing: We do not "sell" or "share" personal information
• Limit the use of sensitive personal information: We do not use sensitive personal information beyond what is necessary to provide the Services
• Right to non-discrimination: The right not to receive discriminatory treatment for exercising the rights above
To exercise these rights, please contact tobongame@gmail.com. We will verify your identity and respond within a reasonable period.
9. Cookies and Similar Technologies
The Website may use localStorage to retain display settings. These do not contain personally identifying information.
You can reject cookies and local storage in your browser settings, but some features may then be unavailable.
If we introduce cookies for purposes such as access analytics in the future, we will revise this Policy and obtain prior consent where necessary.
10. Minors
We do not intentionally collect personal information from anyone under the age of 16. Age verification on distribution platforms (Steam, Google Play, and Apple App Store) is governed by their respective terms.
Minors should use the Services with the consent of, and under the responsibility of, a parent or guardian. If we learn that a child's information has been provided to our studio, we will promptly delete it.
11. Security
We take reasonable and appropriate security measures to prevent the leakage, loss, damage, or other compromise of the personal information we collect.
12. Revisions
We may revise this Policy in response to changes in laws, our business, or other circumstances. We will announce significant changes on the Website. Please review this Policy regularly.
13. Contact
Please send questions or requests regarding this Policy to the contact below.
TOBON GAME