Global Privacy Policy

Effective Date: May 28, 2026

GameWith, Inc. (hereinafter referred to as "the Company," "we," "us," or "our") establishes this Global Privacy Policy (hereinafter referred to as "this Policy") to govern the handling of personal information of users residing outside of Japan (hereinafter referred to as "User" or "you") in connection with the services provided by the Company (hereinafter referred to as the "Services").

For users residing within Japan, this Policy does not apply, and the separate domestic "Privacy Policy" established by the Company shall apply instead.

We strictly comply with applicable global data protection regulations, including the European General Data Protection Regulation (GDPR) and applicable United States state privacy laws (such as the California Consumer Privacy Act as amended by the California Privacy Rights Act (CCPA/CPRA)), to ensure the highest standard of privacy protection for our Users. For specific provisions applicable to residents of particular countries or regions (such as Europe and the United States), please refer to the respective Addenda located at the end of this Policy.

1. Scope and Personal Information We Collect

  • (i) This Policy applies when Users residing outside of Japan use our Services.
  • (ii) We collect and obtain the following categories of personal information through the Services from Users:
    • (a) Information You Provide Directly to Us: Account data (name, email address, username, password, date of birth, gender, profile image) and communication data (contents of inquiries entered via forms, customer support logs, and survey responses).
    • (b) Information Collected Automatically Through Your Use of the Services: Identifiers and device information (IP address, unique device identifiers, advertising identifiers such as IDFA / AAID, OS, and browser type), activity and log data (access timestamps, browsing history within the platform, search queries, operation history, and clickstream data, etc.), and location data (approximate location inferred from IP address or precise GPS data based on your device settings).
    • (c) Information such as identifiers, profile information, and friend relationships that are permitted to be disclosed by the privacy settings of third-party external services (Apple, Google, X, Discord, Facebook, etc.) when the User links the Service with such external services.

2. Purpose of Use

We will only use the personal information we collect for the following purposes. We will not use the information for any purpose other than as permitted by applicable laws and regulations.

  • 2.1 Service Delivery and Management: Provision of the Services, user authentication, account management, functionality enhancement, and customer support.
  • 2.2 Communications and Marketing: Delivery of promotional updates, announcements, campaigns, surveys, and distribution of prizes.
  • 2.3 Security and Fraud Prevention: Monitoring, investigating, and preventing unauthorized access, fraudulent activities, or violations of our Terms (including automated detection mechanisms).
  • 2.4 Analytics and service improvement: Statistical analysis of usage and access, creation of marketing data, and development of service revisions and new features.
  • 2.5 Advertisement Optimization: Delivering tailored, interest-based advertisements, optimizing ad delivery, and tracking performance.

3. Third-Party Sharing and Data Outsourcing

  • 3.1 We do not sell, disclose, or share your personal information with third parties without your prior consent, except where required by law, court orders, or when urgently necessary to protect human life or property.
  • 3.2 We may outsource operational technicalities to trusted service vendors within the minimum scope necessary to achieve our utilization goals:
    • (i) Cloud hosting and infrastructure providers to ensure stable server operations.
    • (ii) Customer care infrastructure vendors to handle user inquiries and support operations.
    • (iii) Data analytics agencies to evaluate and optimize platform traffic patterns.
    • (iv) Advertising networks and behavioral marketing companies to serve relevant ads.

    In these scenarios, we bind all vendors with robust Data Processing Agreements (DPAs) and enforce rigorous compliance oversight.

4. Cookies, Ad Identifiers, and External Transmission

Our Services utilize Cookies and related technologies (including mobile ad tags like IDFA and AAID) to analyze traffic patterns and serve customized advertisements. A comprehensive inventory of active third-party modules, the precise data types transmitted, and technical directions on how you can execute an opt-out (block tracking) are compiled in our separate "External Transmission Policy (Cookie Policy)", which is updated dynamically.

5. Data Security, International Transfers, and Retention

  • 5.1 Security Measures: We deploy rigorous technical, organizational, physical, and administrative guardrails (including data encryption, firewalls, access controls, and anti-malware systems) engineered to defend your personal information against unauthorized exposure, loss, alteration, or breach.
  • 5.2 International Data Transfers: GameWith, Inc. is operated out of Japan. Personal information collected from Users who reside outside of Japan will be transferred to, stored, and processed on servers located in Japan or any other nation where our service providers operate (such as the United States). By using the Services, you acknowledge and consent to the transfer of your personal information outside of your country of residence to Japan or other jurisdictions.
  • 5.3 Retention Period: We retain your personal information only for the duration necessary to satisfy the utilization purposes or as mandated by applicable regulatory retention laws. Expired data is promptly deleted or fully anonymized using secure procedures.

6. Children's Privacy

  • 6.1 We do not knowingly collect personal information from children under the age of 13 (or other minimum age defined by local jurisdiction) without prior verifiable parental consent. If we learn that we have inadvertently collected personal information from a child without parental consent, we will take immediate steps to delete that information from our servers.
  • 6.2 We are not actually aware that we sell or share the personal information of users who are US residents under the age of 16 or European Economic Area (EEA) or UK residents who are under a certain age under the laws of their country of residence to any third party for cross-contextual behavioral advertising without their explicit consent.

7. Your Privacy Rights and How to Exercise Them

Depending on your geographic location and applicable local data protection laws, Users may hold specific statutory rights regarding their personal data (such as the right to request access, notification of the purpose of use, correction, deletion, or suspension of processing). To invoke these rights, please contact our Data Protection Office listed in Section 9. We will respond within a reasonable timeframe in accordance with applicable laws after verifying your identity.

8. Policy Amendments

We reserve the right to modify this Policy periodically to align with legislative developments, updates to our Services, or global compliance benchmarks. Material changes will be brought to your attention through visible site alerts or direct email notifications.

9. Contact Information

If you have any questions or inquiries about this policy, please contact us at:

Name: GameWith, Inc.
Address: 4F Sumitomo Fudosan Azabu-juban Bldg., 1-4-1 Mita, Minato-ku, Tokyo, Japan
Email: customer-support-en@gamewith.co.jp

Addendum A: Provisions for Residents of the EEA and the United Kingdom (GDPR Compliance)

This Addendum provides additional information and outlines specific rights for users residing in the European Economic Area (EEA) and the United Kingdom (hereinafter referred to as "European Users") pursuant to the GDPR and the UK Data Protection Act.

1. Legal Basis for Processing Personal Data

We process the personal data of European Users under the following lawful bases specified by the GDPR:

  • Consent: Where you have given clear consent for us to process your personal data for a specific purpose (e.g., optional marketing cookies). You have the right to withdraw consent at any time.
  • Performance of a Contract: Where processing is necessary to fulfill our obligations under our contract/Terms of Service to deliver the Services to you.
  • Compliance with Legal Obligations: Where processing is necessary to comply with applicable statutory laws.
  • Legitimate Interests: Where processing is necessary for our legitimate business interests (e.g., maintaining platform security, fraud prevention, traffic analysis, and delivering relevant advertising), provided they do not override your privacy rights.

2. Safeguards for International Data Transfers

We may collect personal data directly from users residing within the EEA or the United Kingdom. Furthermore, when transferring and processing the collected personal data to servers located in Japan or other jurisdictions, we will implement appropriate safeguards in accordance with applicable laws and regulations—such as relying on the adequacy decisions between Japan and the EU/UK, or entering into Standard Contractual Clauses (SCCs)—and manage such data in an appropriate manner.

3. Rights of European Users

European Users hold the following statutory rights regarding their personal data: right of access, rectification, erasure (the "Right to be Forgotten"), restriction of processing, objection, data portability, and the right to withdraw consent at any time. To invoke these rights, contact us via the details in Section 9. You also have the right to lodge a complaint with a data protection supervisory authority in your country.

Addendum B: Provisions for United States Residents (CCPA/CPRA Compliance)

This Addendum provides additional disclosures and outlines specific rights for users residing in California or states with comparable consumer privacy frameworks (hereinafter referred to as "US Users") pursuant to state privacy laws, including the California Consumer Privacy Act as amended by the California Privacy Rights Act.

1. "Sale" or "Sharing" of Personal Information

We do not sell your personal information to third parties for monetary compensation. However, we utilize external ad networks and social media platforms to facilitate cross-context behavioral marketing (tailored advertisements). This involves sharing identifiers and browsing activity via Cookies, which may qualify as a "sale" or "sharing" under CCPA/CPRA frameworks.

2. Categories of Personal Information Collected and Disclosed in the Preceding 12 Months

Pursuant to statutory definitions under US state privacy laws, the categories of personal information we have collected and disclosed to third parties for business optimization or operational purposes over the past 12 months are as follows:

  • Identifiers: Name, username, email address, IP address, Cookie IDs, device IDs, and mobile ad tags (IDFA/AAID, etc.).
  • Commercial Information: Inquiry data, survey feedback, and sweepstakes or campaign entry records.
  • Internet or Other Electronic Network Activity Information: Platform browsing logs, search queries, in-app action logs, and clickstream sequences.
  • Geolocation Data: Coarse location derived from IP addresses or precise GPS metrics dependent on device settings.

3. Privacy Rights of US Users and How to Opt-Out

US Users hold the statutory rights regarding their personal information collected, sold, or shared over the past 12 months: the right to know (access), delete, correct inaccuracies, and opt-out of the "sale" or "sharing" of data. You will not receive discriminatory treatment for exercising your rights.

If you wish to opt-out of the "sale" or "sharing" of your personal information, you can manage or withdraw your consent at any time using the cookie consent settings button displayed at the bottom-right of the screen on our websites. We also detect and honor Global Privacy Control (GPC) signals broadcast by your browser as valid opt-out requests. Please note that your consent preferences are managed separately for each of our websites, so you will need to update your settings on each site you use.