The following is the “Crypt Busters Privacy Policy” (hereinafter referred to as the “Policy”) regarding the handling of personal information that Ateam Entertainment Inc. (Headquarters: Dai Nagoya Building 32F, 28-12 Meieki 3-chome, Nakamura-ku, Nagoya 450-6432, Japan; Director: Yukimasa Nakauchi; Hereinafter referred to as the “Company”) obtains from users through the Crypt Busters service operated and provided by the Company on the Company’s website (hereinafter referred to as the “Service”)

Terms used in this policy shall have the meanings set forth in the “Crypt Busters Terms of Use” (hereinafter referred to as the “Terms”), which is separately defined by the Company. The terminology used in this Policy shall mean the “Crypt Busters Terms of Use” (hereinafter referred to as the “Terms”) and the “Act on the Protection of Personal Information” (Act No. 57 of 2003, hereinafter referred to as the “Personal Information Protection Act”, including its enforcement order, enforcement regulations and guidelines published by the Personal Information Protection Commission), as separately stipulated by the Company. The Company shall comply with the following provisions of the Act on the Protection of Personal Information (hereinafter referred to as the “Act”). The Company shall not disclose personal information to any third party without the prior written consent of the individual concerned, and shall not disclose such personal information to any third party without the prior written consent of the individual concerned. This Privacy Policy shall be governed by the “Personal Information Protection Law”.

1. Collected Personal Information

The company may obtain the following information from you.

1. Contact information
2. Usage history
3. Cookies
4. Other information that is necessary for us to obtain in order to provide this service
   • IP address
   • Locale, timezone
   • Mobile device type and OS version
   • Mobile device identifier
   • ID, password
   • Referer Information

2. Use of Personal Information

Obtained personal information may be used for the following purposes. In case we have also had your separate consent to use your personal information for purposes different from those listed below when you provided it to us, we will also use the information within the scope of those purposes.

1. To accept registrations, verify user identity, authenticate users, and record user preferences related to the Service.
2. To provide and implement game user account information, other services, etc. required for use of this service, and to provide related communications, guidance and various types of information.
3. To help in the development of related services, system maintenance, investigation of causes of malfunctions, improvement, and enhancement of the service.
4. To provide and conduct events, questionnaires, prize competitions, campaigns, etc. related to the service, as well as to contact, guide and provide various information related to such events, questionnaires, prize competitions, campaigns, etc.
5. For marketing research, statistics or analysis related to this service.
6. To measure traffic and user behavior.
7. To respond to various inquiries, requests or demands from users.
8. To improve the quality of the service.
9. To respond to fraudulent or illegal activities related to the service and to prevent illegal or potentially illegal activities.
10. To notify important matters such as the execution of these Rules and Regulations or any related changes.
11. To provide to third parties to the extent necessary to achieve the purpose of use stipulated by the service.
12. For other purposes as specified in the services provided by the service.

3. Provision of Personal Data to Third Parties

1. We will not provide personal data to third parties without the prior consent of the user, except as required by law.
2. We may provide your personal data to a third party located in a foreign country in connection with the outsourcing of work related to the provision of this service, taking measures required under Japan’s Personal Information Protection Law. In such cases, users who wish to have information disclosed, including the measures we have taken and the foreign country to which the information is provided, they should refer to the article “9. Contact for consultations and complaints regarding the handling of personal information”.

4. Outsourcing

We may outsource all or part of our services related to the Service, including data analysis, emailing, hosting services, customer service, marketing support, maintenance services, and the development and provision of products and services related to the service, to outside parties. We may also outsource all or part of the handling of personal data to subcontractors to the extent necessary to achieve the purpose of use. In this case, we will select a contractor that ensures an appropriate level of personal information protection to ensure the safe management of personal data. In addition, we will enter into contracts with contractors, obligate such contractors to appropriately manage personal data in a secure manner, and supervise them appropriately.

5. Shared Use of Personal Data

We may share personal data as follows.

1. Parties with whom the information will be shared (hereinafter referred to as “Partner”)
   See below for details of our group companies.
   https://www.ateam-entertainment.com/en/about/
2. Items of personal data to be shared
   Information described in “1. Collected Personal Information”
3. Purpose of shared use
   
   1. To accept registrations, verify user identity, authenticate users, and record user preferences related to the service.
   2. To provide and implement game user account information, other services, etc. required for use of this service, and to provide related communications, guidance and various types of information.
   3. To help develop, improve, and enhance services related to the service or partners.
   4. To develop, distribute, and provide advertisements for the service or services related to partners, and to confirm the results of such advertisements.
   5. To provide and conduct events, questionnaires, prize competitions, and campaigns related to the service or partners, and to communicate, guide, and provide various types of information related to such events, questionnaires, prize competitions, and campaigns.
   6. For marketing research, statistics, and analysis related to the service or partners.
   7. To measure traffic and user behavior.
   8. To help in the development of related services, system maintenance, investigation of causes of malfunctions, improvement, and enhancement of the service.
   9. To respond to various inquiries, requests or demands from users.
   10. To respond to fraudulent or illegal activities related to the service and to prevent illegal or potentially illegal activities.
   11. To notify important matters such as the execution of these Rules and Regulations or any related changes.
   12. For other purposes as specified in the services provided by the service.
4. Party responsible for management of shared use
   Business Name: Ateam Entertainment Inc.
   Headquarters: Dai Nagoya Building 32F, 28-12 Meieki 3-chome, Nakamura-ku, Nagoya 450-6432, Japan
   Representative: Director Yukimasa Nakauchi
   

6. Personal Data Protection and Security Measures

1. Formulation of basic policy
   We have established the “Privacy Policy” as our basic policy to ensure the proper handling of personal data.
2. The handling of personal data
   The Company will establish internal rules and guidelines regarding the method of handling personal data and the management system.
3. Organizational safety management measures
   We will appoint a personal information protection manager to clarify the scope of personal data handled by officers and employees, have the personal information protection manager supervise officers and employees, and establish a reporting and communication system in the event that any fact or sign of violation of laws, regulations, or internal rules is detected.
4. Human security management measures
   The Company will regularly educate its directors and employees on the points to keep in mind regarding the handling of personal data.
5. Physical and technical safety control measures
   In order to prevent leakage, loss or damage, theft or misuse, and falsification of personal data, we will control access to rooms and limit the equipment, etc. that are brought in, as well as take reasonable physical and technical measures such as locking equipment, electronic media and documents that handle personal data, data encryption, access control and measures to prevent unauthorized access, and will operate them appropriately.
6. Understanding the external environment
   When handling personal data in a foreign country, we will take necessary and appropriate measures for the secure management of personal data, based on our knowledge of the systems for the protection of personal data in that foreign country.
7. Inquiries
   If you would like to confirm the details of the security control measures we take, please contact the “Personal Information Response Desk” listed in “9. Contact for consultations and complaints regarding the handling of personal information”.

7. Procedures for Requesting Disclosure, etc. of Retained Personal Data

In accordance with the Personal Information Protection Law, users may ask the Company to disclose retained personal data or records provided to third parties, and to correct, add to, delete, stop using, etc. or stop providing to third parties retained personal data as follows. In such cases, we will disclose the information without delay or disclose it to the extent necessary after confirming that the request is made by the person in question and that the requirements stipulated in the Act are met. However, this shall not apply in cases where the Company is not obligated to do so under the Act or other laws and regulations.

1. Disclosure of retained personal data or records provided to third parties.
   The individual whose personal data is retained may, to the extent permitted by the Personal Information Protection Law, request us to disclose his/her personal data or records provided to a third party by a method designated by the individual, such as by providing an electromagnetic record or by delivering a document. If it is difficult to disclose the information by the specified method, we will notify the person in question without delay.
2. Corrections, additions and deletions
   The individual whose personal data we hold may request us to correct, add to, or delete their personal data in accordance with the provisions of the Personal Information Protection Law. In such cases, we will investigate without delay to the extent necessary to achieve the purpose of use, and correct, add, or delete such retained personal data to the extent permitted under the Act.
3. Suspension of use, etc. or suspension of provision to third parties
   The individual whose personal data is retained may request us to stop using or erase the personal data or to stop providing the data to a third party, in accordance with the provisions of the Personal Information Protection Law. In such cases, we will respond appropriately in accordance with the Act.
4. Procedures
   When making a request for disclosure, etc., the user shall fill in the prescribed items on the request form prescribed by the Company, attach materials designated by the Company, and mail the form to the mailing address designated by the Company. In addition, a prescribed fee will be charged for notification of the purpose of use and disclosure of retained personal data or information provided to a third party. Please note that even in the case of nondisclosure or non-disclosure of the purpose of use, the prescribed fee will be charged. If you would like to request a copy, please contact us using the Inquiries form.

8. Disposal, etc. of Acquired Personal Data

Personal data acquired will be disposed of, deleted, or erased without delay as soon as it is deemed reasonably unnecessary in light of the Company’s normal business operations and purposes of use.

9. Contact for Consultations and Complaints Regarding the Handling of Personal Information

The Company has established the following contact point to handle complaints and consultations regarding personal information.

Ateam Entertainment Inc. Personal Information Response Desk
【Discord】 https://discord.gg/WFjgpmczxe
*Please contact Support bot via DM

10. Handling of Cookies

1. Use of cookies and web beacons
   We collect statistical site usage information, such as cookies and web beacons, to improve the usability of our services, analyze statistical data, and measure the effectiveness of advertising.
   1. About cookies
      Cookies are pieces of information that a web server sends and receives between the browsers of users of our web site so that they can use our web site comfortably. Users of our services may set their browser to refuse cookies, but please note that if they do so, they may not be able to use all or part of the services provided by our Web site. Please note that we are not responsible for the handling of personal information on websites that are linked to our website and are operated by websites other than ours.
   2. About web beacons
      Web beacons are small image files embedded in websites, which enable us to understand statistical data such as the presence or absence of visits to a website and the number of times a visitor has visited. Web beacons do not contain personally identifiable information.
2. Advertising distribution of our services by third-party distribution providers
   Advertisements for our services are displayed on sites on the Internet by third-party distributors such as Google, Facebook, and Twitter. These third-party distribution providers use cookies and other identifying information to distribute advertisements based on information about past accesses to our website. In addition, we may encrypt personal information held by us and distribute advertisements based on the results of matching it with information held by these third-party distribution providers. These third-party service providers will not use such encrypted information for any purpose other than the delivery of advertisements. Please refer to the following for information on the main third-party service providers used in the applications or software operated by the Company and the procedures for disabling the delivery of advertisements (opt-out) by such third-party service providers.
   

   	Privacy Policy	How to opt-out
   1. Google LLC	https://policies.google.com/privacy?hl=en&gl=en	https://support.google.com/ads/answer/2662922?hl=en
   2. Meta Platforms, Inc.	https://www.facebook.com/legal/terms	https://www.facebook.com/help/109378269482053?helpref=hc_global_nav
   3. Twitter, Inc.	https://twitter.com/en/privacy	https://help.twitter.com/en/safety-and-security/privacy-controls-for-tailored-ads

3. About ad serving using Facebook Custom Audience
   We use Facebook Custom Audience to display advertisements based on the usage of our services. For more information, please visit Facebook Custom Audiences (https://facebook.com/business/help/744354708981227?id=2469097953376494). To disable ad delivery using Facebook Custom Audience, please refer to Facebook’s opt-out page (https://www.facebook.com/about/ads) and follow the procedures.
4. Use of access analysis tools
   Our service introduces various access analysis tools provided by third-party companies for the purpose of improving our website and our services. With these analysis tools, information related to actions taken on our website and services, such as URLs and IP addresses related to pages viewed by customers, is transmitted to the relevant third party for analysis. Such data is collected anonymously and does not personally identify you. However, for the purpose of displaying information that may be of interest to you on the Web site or within the service, we may link such analysis information with personal information we have about you and use it to understand usage conditions and the service. Information collected directly by third-party companies is managed in accordance with the privacy policies set forth by the third-party companies. The following are the main access analysis tools related to the applications and software we provide. Please refer to the links below for the privacy policy of each analysis tool used for each service and the relevant analysis tool.

   	Terms of Service
   1. Social Insight (User Local, Inc.)	https://social.userlocal.jp/document/terms_social/
   2. Google Analytics (Google LLC)	https://marketingplatform.google.com/about/analytics/terms/us/
   3. Firebase Analytics (Google LLC)	https://firebase.google.com/terms/analytics

11. Changes to Privacy Policy

We may change this policy from time to time, and any changes will be posted on our website. Users are advised to carefully review the latest version of this Policy posted on the website.

Date of adoption: 5/24/2023