株式会社ルーデル

Privacy Notice

Last Updated: April 23, 2024

This Privacy Notice describes the personal information that Rudel, Inc. ( “we,” “us,” or “our”) collects, uses, discloses, and otherwise processes about individuals (“you,” “your,”), the rights and choices your have regarding your personal information (including personal data), and other important matters regarding the protection of your personal information. For some of our products and services, their specific privacy policies or supplemental privacy notices may be provided and applied.

While we may provide various translations of this Notice as a reference, to the extent permitted by Applicable Laws, the Japanese version applies to users using our Services in Japan, and the English version applies to users using our Services in other countries or regions.

Additional information for residents of specific state or area

If you are a resident of a particular state or area, please see the relevant section listed in the Table of contents below for additional information for that state or area’s residents.

Table of contents

This Privacy Notice applies to personal information processed by us, including on our websites, mobile applications, blog and other online or offline offerings. To make this Privacy Notice easier to read, our websites, mobile applications, blog and other offerings are collectively called “Services.”

We may revise this Privacy Notice from time to time in our sole discretion. Any changes will become effective when we post the revised Privacy Notice on the Services. You understand and agree that you will be deemed to have accepted the updated Privacy Notice if you continue to use our Services after the new Privacy Notice takes effect.

The categories of personal information we collect depend on how you interact with us, our Services and the requirements of applicable law. We collect information that you provide to us, information we obtain automatically when you use our Services, and information from other sources such as third-party services and organizations, as described below. Additionally, We do not collect, use, disclose, sell, or share any of your sensitive personal information.

A. Information You Provide to Us Directly
To offer our users certain features of our Services, and to create certain user accounts (e.g., to create a game account), we collect several types of personal information from you directly. Typically, this information includes:
  • ・User name / ID
  • ・Email address
  • ・Personal information that you submit or make available through our interactive features (e.g., messaging and chat features, and social media pages)
  • ・Other information to help you with your experience
B. Information Collected Automatically
We collect your personal information automatically when you use our Services, including sometimes through cookies and other Web-Based Technologies. Typically, this information includes:
  • ・IP address
  • ・Device identifiers
  • ・Browser information, including browser type
  • ・Details about the Services you are using and your use of them, such as
    • ・User data
    • ・Play data
    • ・Logs
    • ・Payment information
  • ・Location Information. We may collect precise location information, such as location information from your mobile device or otherwise use our Services if you opt in to permit us to do so.
  • ・Cookies, Pixel Tags/Web Beacons, and Other Technologies. We, as well as third parties that provide content, advertising, or other functionality on our Services, may use cookies, pixel tags, local storage, and other technologies (“Technologies”) to automatically collect information through your use of our Services.
    • ・Cookies. Cookies are small text files placed in device browsers that store preferences and facilitate and enhance your experience.
    • ・Pixel Tags/Web Beacons. A pixel tag (also known as a web beacon), is a piece of code embedded in our Services that collects information about engagement on our Services. The use of a pixel tag allows us to record, for example, that a user has visited a particular web page or clicked on a particular advertisement. We may also include web beacons in e-mails to understand whether messages have been opened, acted on, or forwarded.
Our uses of these Technologies fall into the following general categories:
  • ・Operationally Necessary. This includes Technologies that allow you access to our Services, applications, and tools that are required to identify irregular website behavior, prevent fraudulent activity and improve security or that allow you to make use of our functionality;
  • ・Performance-Related. We may use Technologies to assess the performance of our Services, including as part of our analytic practices to help us understand how individuals use our Services (see Analytics below);
  • ・Functionality-Related. We may use Technologies that allow us to offer you enhanced functionality when accessing or using our Services. This may include identifying you when you sign into our Services or keeping track of your specified preferences, interests, or past items viewed;
  • ・Advertising- or Targeting-Related. We may use first-party or third-party Technologies to deliver content, including ads relevant to your interests, on our Services or on third-party websites.
See Section 6 below to understand your choices regarding these Technologies.
  • ・Analytics. We may use Technologies and other third-party tools to process analytics information on our Services. Some of our analytics partners include:
    • ・Google Analytics. For more information, please visit Google Analytics’ Privacy Policy. To learn more about how to opt-out of Google Analytics’ use of your information, please click here.
    • ・Social Media Platforms. Our Services may contain social media buttons such as Facebook (that might include widgets such as the “share this” button or other interactive mini programs). These features may collect your IP address, which page you are visiting on our Services, and may set a cookie to enable the feature to function properly. Your interactions with these platforms are governed by the privacy policy of the company providing it.
Information Collected from Other Sources
We may obtain information about you from other sources, including through our group companies or third-party services and organizations. For example, if you access our Services through a third-party application, such as an app store we may collect information about you from that third-party application. Additionally, when you complete in-app purchases, we may collect information about you from the provider of your device operating system when they process the purchases on our behalf. Please note that we have not received information on your payment method from the operating system providers.
We may use the personal information we collect for the following purposes:
Purposes Legal basis of processing
To provide and improve various services operated by us, to plan and develop new services, and to introduce such services.
  • ・Performance of contract
  • ・Our legitimate interest to administer and improve our services and give our users the best experience.
To bill or pay for the Service's usage fees and other payments
  • ・Performance of contract
To survey and analyze the use of the Service, and to prepare and publish statistical data
  • ・Our legitimate interest to administer and improve our services and give our users the best experience
  • ・Consent
To authenticate, identify, or screen customers when they use the Service or make inquiries.
  • ・Performance of contract
To customize the contents of the Service to suit the customer.
  • ・Performance of contract
  • ・Our legitimate interest to administer and improve our services and give our users the best experience.
To survey customer satisfaction with the Service.
  • ・Our legitimate interest to administer and improve our services and give our users the best experience.
To advertise or promote the services of us or third parties who act as advertisers.
  • ・Our legitimate interest to administer and improve our services and give our users the best experience
  • ・Consent
For marketing of products and services of us or third parties.
  • ・Our legitimate interest to administer and improve our services and give our users the best experience
  • ・Consent
For drawing lots and sending prizes for campaigns, etc.
  • ・Performance of contract
To award points (including those issued by third parties)
  • ・Performance of contract
To prevent the use of this service in a manner that violates the Terms of Service.
  • ・Our legitimate interest to administer and improve our services and give our users the best experience
  • ・Legal obligation
To investigate, detect, and prevent fraud, unauthorized access, and other illegal activities using the Service, and to respond to such activities.
  • ・Our legitimate interest to administer and improve our services and give our users the best experience
  • ・Legal obligation
To resolve problems in the operation of the Service.
  • ・Performance of contract
  • ・Our legitimate interest to administer and improve our services and give our users the best experience
We disclose your information to third parties for a variety of business purposes, including to provide our Services, to protect us or others, or in the event of a major business transaction such as a merger, sale, or asset transfer, as described below.
A. Disclosures to Provide our Services
The categories of third parties with whom we may share your information are described below.
  • ・Service Providers. We may share your personal information with our third-party service providers who use that information to help us provide our Services. This includes service providers that provide us with IT support, hosting, payment processing, customer service, and related services.
  • ・Group Companies/Affiliates. We may share your personal information with our company affiliates.
  • ・Advertising Partners. We may share your personal information with third-party advertising partners. These third-party advertising partners may set Technologies and other tracking tools on our Services to collect information regarding your activities and your device (e.g., your IP address, cookie identifiers, page(s) visited, time of day). These advertising partners may use this information (and similar information collected from other services) for purposes of delivering personalized advertisements to you when you visit digital properties within their networks. This practice is commonly referred to as “interest-based advertising” or “personalized advertising.”
B. Disclosures to Protect Us or Others
We may access, preserve, and disclose any information we store associated with you to external parties if we, in good faith, believe doing so is required or appropriate to: comply with law enforcement or national security requests and legal process, such as a court order or subpoena; protect your, our, or others’ rights, property, or safety; enforce our policies or contracts; collect amounts owed to us; or assist with an investigation or prosecution of suspected or actual illegal activity.
C. Disclosure in the Event of Merger, Sale, or Other Asset Transfers
If we are involved in a merger, acquisition, financing due diligence, reorganization, bankruptcy, receivership, purchase or sale of assets, or transition of service to another provider, your information may be sold or transferred as part of such a transaction, as permitted by law and/or contract.
Your Privacy Choices. The privacy choices you may have about your personal information are determined by applicable law and are described below.
  • ・Mobile Devices. We may send you push notifications through our mobile application. You may opt out from receiving these push notifications by changing the settings on your mobile device.
  • ・Cookies and Interest-Based Advertising. You may stop or restrict the placement of Technologies on your device or remove them by adjusting your preferences as your browser or device permits. However, if you adjust your preferences, our Services may not work properly. Please note that cookie-based opt-outs are not effective on mobile applications. However, you may opt-out of personalized advertisements on some mobile applications by following the instructions for Android, iOS and others.
    For more information about setting cookies, visit here.
    Please note you must separately opt out in each browser and on each device.
  • ・“Do Not Track.” At this time, Our websites do not recognize browser-based “Do Not Track” instructions. You can, however, change your privacy preferences regarding the use of cookies and similar technologies through your browser, as mentioned above.
Your Privacy Rights. In accordance with applicable law, you may have the right to:
  • ・Access Personal Information about you, including: (i) confirming whether we are processing your personal information; (ii) obtaining access to or a copy of your personal information; and (iii) receiving an electronic copy of personal information that you have provided to us, or asking us to send that information to another company (the “right of data portability”);
  • ・Request Correction of your personal information where it is inaccurate or incomplete. In some cases, we may provide self-service tools that enable you to update your personal information;
  • ・Request Deletion of your personal information;
If you would like to exercise any of these rights, please contact us as set forth in Section 13 below. You can use our online web form for Request Deletion located at here. We will process such requests in accordance with applicable laws.
We take reasonable technical and organizational measures to help protect your personal information from loss, theft, misuse and unauthorized access, disclosure, alteration and destruction. However, no transmission over the internet can ever be guaranteed secure so we cannot guarantee the security of any personal information that you transfer over the internet to us.
We store the personal information we collect as described in this Privacy Notice for as long as you use our Services or as necessary to fulfill the purpose(s) for which it was collected, provide our Services, resolve disputes, establish legal defenses, conduct audits, pursue legitimate business purposes, enforce our agreements, and comply with applicable laws. The specific retention period is determined based on the purpose of acquisition and processing, the nature of the personal data, and its necessity for legal or business grounds.
This U.S. Privacy Notice (this “Notice”) covers our information collection practices and describes your rights regarding your personal information for the United States of America (U.S.) residents.
All terms defined in the privacy laws of the states of the U.S. (respectively and collectively, the “State Privacy Law(s)”) have the same meanings when used in this section.
Categories of personal information we collect
U.S. residents with the right to know what categories of personal information we collected about them and whether we disclosed that personal information for a business purpose (e.g., to a service provider) in the preceding 12 months. U.S. residents can find this information below:
Category of Personal Information Collected by Us Category of Third Parties Information is Disclosed to for a Business Purpose
Identifiers.
Examples: User ID, Player name, Email address, IP address, Device identification number
  • ・Group Companies
  • ・Advertising networks
  • ・Data analytics providers
  • ・Service Providers
Protected classification characteristics under California or federal law
Examples: Age (40 years or older), Sex (including gender, gender identity)
  • ・Group Companies
  • ・Service Providers
Commercial information
Examples: Products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies
  • ・Group Companies
  • ・Advertising networks
  • ・Data analytics providers
  • ・Service Providers
Geolocation data
Example:Physical location or movements.
  • ・Group Companies
  • ・Advertising networks
  • ・Data analytics providers
  • ・Service providers
Internet or other similar network activity
Examples: Browsing history, Search history, Information on a consumer's interaction with an internet website, application, or advertisement
  • ・Group Companies
  • ・Advertising networks
  • ・Data analytics providers
  • ・Service Providers
Professional or employment-related information
Example: Occupation
  • ・Group Companies
  • ・Service Providers
The categories of sources from which we collect personal information and our business and commercial purposes for using personal information are set forth above.
“Sales” or “Share” of Personal Information under the State Privacy Law
For the purposes of the respective State Privacy Laws, we do not sell or share your personal information, including personal information of children under the age of 16, and we have not sold or shared any personal information during the 12 months preceding the effective date of this Notice.
Additional Privacy Rights for U.S. Residents
You may exercise the following rights by contacting us or a representative or data protection officer. If you request to exercise the following rights, please contact us as set forth in section 13 below.
  • ・Non-Discrimination. U.S. residents have the right not to receive discriminatory treatment by us for the exercise of their rights conferred by respective State Privacy Laws.
  • ・Authorized Agent. Only you, or someone legally authorized to act on your behalf, may make a verifiable consumer request related to your personal information. You may also make a verifiable consumer request on behalf of your minor child. To designate an authorized agent, please contact us as set forth in section 13 below.
  • ・Verification. To protect your privacy, we will take steps the following steps to verify your identity before fulfilling your request. When you make a request, we will ask you to provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative.
If you are a U.S. resident and would like to exercise any of your rights under respective State Privacy Laws, please contact us as set forth in Section 13 below. We will process such requests in accordance with applicable laws.
  • ・California Shine the Light. We are exempted from the requirement to grant such a request because we do not disclose personal information of customers for third parties’ direct marketing purposes unless a customer directs to us.
  • ・Privacy Rights for California Minors in the Digital World. If you are under the age of 18, you have the right to request permanent deletion of the reviews of products you posted on our service. Please note that, when you post the reviews they can be collected, stored, or shared by others, and we cannot delete such information held by others.If you request to exercise the above rights, please contact us as set forth in section 13 below.
This Supplemental GDPR Privacy Notice only applies to our processing of personal data that is subject to the General Data Protection Regulation (Regulation (EU) 2016/679 of 27 April 2016) and equivalent laws of the United Kingdom of Great Britain and Northern Ireland (the “UK”)(“GDPR”). This Notice is applicable only to personal data concerning data subjects (“you” or “your”) in the member states of the European Union and three EEA/EFTA states - Iceland, Liechtenstein and Norway (collectively, the “EU”) and the UK.
For purposes of this notice, the terms defined under the GDPR have the meanings ascribed to them under the GDPR.

We are responsible for your personal data as a data controller. If you have any questions or would like to uphold your rights, please contact us at;
Email: support@bluelock-pwc-gl.net
Transfers to third countries outside the EU
Personal data that we collect from you is usually transferred, stored, and processed in Japan. The third parties to which we transfer your personal data in order to provide our services (please see “ HOW WE DISCLOSE YOUR INFORMATION” above) are located in Japan. Japan is recognized by the European Commission as providing an adequate level of data protection.
No obligation to provide your personal data
You have no obligation to provide your personal data to us either under applicable law or a contract. Once you make an order for our services, we may require your personal data based on the contract with you, in which case your failure to provide the personal data we require may prevent us from providing you with the services.
Profiling
We will not make decisions based solely on automated processing, including profiling on collected personal data, which produces legal effects concerning the User or similarly significantly affects the User.
Additional Privacy Rights for EU Residents
You may exercise the following rights by contacting us or a representative or data protection officer. If you request to exercise the following rights, please contact us as set forth in section 13 below.
  • ・Right to erasure. You may obtain the erasure of your personal data, subject to certain exceptions under the GDPR, where: (i) such personal data is no longer necessary in relation to the purposes for which we collected and processed it; (ii) you withdraw your consent to our processing solely based upon your consent; (iii) you object to our processing and there are no overriding legitimate grounds for such processing; (iv) our processing is unlawful; (v) your personal data has to be erased in compliance with a legal obligation.
  • ・Right to restriction of processing. You may obtain restriction of processing of your personal data, subject to certain exceptions under the GDPR, where: (i) you contest the accuracy of your personal data: (ii) our processing is unlawful and you select to restrict our processing instead of requesting erasure of your personal data: (iii) you request us to establish, exercise or defense legal claims that need your personal data no longer necessary for the purposes of our processing; or (iv) you exercise the right to object to our processing and wait for verification on where we have overriding legitimate grounds.
  • ・Right to data portability. You may receive your personal data or direct us to transmit your personal data to a third party you designate, provided that we process such personal data based upon your consent or as the performance of a contract with you.
  • ・Right to object. You may object to processing of your personal data where our processing is based upon the exercise of our official authority or our legitimate interests, including “profiling” or for direct marketing purposes.
  • ・Right to the withdrawal of your consent. You may withdraw your consent at any time to the processing of your personal data that we have collected about you. The legality of processing based on consent prior to withdrawal will not be affected by withdrawal of consent.
  • ・Right to complain. You may lodge a complaint with the supervisory authority, in particular, in the member state of the EU or the UK where you have a habitual residence or place or work or where the alleged infringement of GDPR took place.
The Services are not directed to children under 13 in the United States, and under the applicable age of consent in other countries ("Child" or "Children"). We do not knowingly collect or store personal information from Children. However, we do collect information, including personal information, from all users of the Services. If you believe we may have unintentionally collected personal information from your Child, please contact us as set forth below.
The Services may contain links to other websites/applications and other websites/applications may reference or link to our Services. These third-party services are not controlled by us. We encourage our users to read the privacy policies of each website and application with which they interact. We do not endorse, screen or approve, and are not responsible for, the privacy practices or content of such other websites or applications. Providing personal information to third-party websites or applications is at your own risk.
If you have any questions about our privacy practices or this Privacy Notice, or to exercise your rights as detailed in this Privacy Notice, please contact us at:

Email: support@bluelock-pwc-gl.net

Additionally, if you reside in the EEA, you can contact our Data Protection Officer, European representative, UK representative, or file a complaint with the supervisory authorities in Europe, the UK.
  • ・Representative
    Our representative in the EU/UK is Classmethod (Europe) GmbH. You can contact our representative at;
    Mail: Krausenstr.9 -10, 10117 Berlin, Germany
    Email: rh@gdpr-contact.email
  • ・Data Protection Officer
    You can contact our Data Protection Officer at;
    Mail: Rudel Inc. 1-6-1 Yotsuya, Shinjuku-ku, Tokyo 160-0004
    Email: dpo@reazon.jp

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