This English text is a reference translation (machine-assisted). The Japanese version is the official text and prevails in case of any discrepancy.

Version 1

"Keeper's Isle" Privacy Policy

野田晶裕 (the "Operator") handles users' information in the smartphone game "Keeper's Isle" (the "Service") as follows.

1. Information We Collect and How

• We do not collect names, postal addresses, telephone numbers or credit card numbers (payments are processed by the Store).
• We do not collect e-mail addresses within the app (we receive an e-mail address only when you contact us from outside the app).
• We do not collect contacts, photos, videos, audio, files, calendars or precise location.
• The Service does not provide free-text chat.

2. Purposes of Use

We use the information we collect for the following purposes.

1. 1. Providing the Service (account management, saving and syncing game data, rankings, co-op connections, processing of the Market and direct exchange, inbox management)
2. 2. Confirming, granting and restoring purchases of paid items, and processing refunds
3. 2-2. Conducting paid draws, storing and displaying the results to you, verifying that draws follow the displayed odds (aggregating appearance rates), and responding to inquiries
4. 3. Calculating the age category from the year and month of birth and applying the monthly purchase limit by age category (under 18), blocking purchases where the year and month of birth or consent to the Terms is missing, restricting use by persons under 13, and age-appropriate advertising settings
5. 3-2. Recording consent to the Terms of Service and Privacy Policy and confirming consent upon revision
6. 4. Preventing, detecting and investigating fraud (RMT, misuse of multiple accounts, cheating and modification, bots, exploitation of bugs, etc.) and taking measures under the Terms of Service (holding or cancelling trades, recovering items, suspending accounts, etc.)
7. 5. Verifying ranking records (replaying input logs to confirm results) and displaying ghosts (movement reproduced from input logs), display names and records to other users
8. 6. Delivering advertisements, confirming views of rewarded ads and granting rewards, and measuring ad effectiveness
9. 7. Responding to inquiries and sending important notices
10. 8. Investigating and improving defects in the Service (including responding to bug reports and crash reports), and producing statistics (in a form that does not identify individuals) for considering new functions and services
11. 9. Responding to users who violate the Terms of Service, and complying with laws

3. Provision to Third Parties

We do not provide personal data to third parties except in the following cases.

1. 1. With your consent
2. 2. Where required by law (such as lawful requests from investigative authorities)
3. 3. Where necessary to protect a person's life, body or property and it is difficult to obtain your consent
4. 4. Where we entrust handling to the service providers in Section 4 to the extent necessary to achieve the purposes of use
5. 5. Where provided in connection with a business succession

Information Visible to Other Users

The following information is displayed to other users as part of how the Service works (we list it here on the premise that this is not provision to third parties).

4. Service Providers and External Services

To provide the Service, we entrust the handling of information to, or use the services of, the following providers.

5. Provision to Third Parties in Foreign Countries (Storage Abroad)

1. 1. As described in Section 4, we may entrust the handling of personal data to, or provide personal data to, providers located in the United States (Unity Technologies, Cloudflare, Inc., Google LLC, Apple Inc., Microsoft Corporation).
2. 2. Personal information protection system of the destination country: the United States has no comprehensive federal law equivalent to Japan's Act on the Protection of Personal Information; there are state laws (such as the California Consumer Privacy Act) and sector-specific laws. Please refer to the materials of Japan's Personal Information Protection Commission ( https://www.ppc.go.jp/personalinfo/legal/kaiseihogohou/#gaikoku ).
3. 3. Measures taken by the recipients: [Unity Technologies takes the measures of ... under its Data Processing Agreement (DPA).]
4. 4. When you first launch the Service (before connecting to our server), we explain that your play records, purchase records and other data are stored on servers of providers located outside Japan (such as the United States) and obtain your consent to this Policy (Act on the Protection of Personal Information, Article 28, paragraph 1).

6. Personally Referable Information (Advertising IDs, etc.)

We allow the advertising providers in Section 7 to collect information that by itself cannot identify a specific individual, such as advertising IDs, device information and ad impression records. Where it is expected that these providers will obtain such information in a way that links it to personal data they hold, we confirm, in accordance with the law, that your consent has been obtained.

7. Data Sent to Third Parties (Information Transmitted from Your Device to Others)

In the Service, information is transmitted from your device to providers other than the Operator as follows.

How to Stop Ad Tracking

• Android: you can delete or reset the advertising ID from the device's [Settings → Google → Ads].
• iOS: you can decline tracking in the prompt shown when you first launch the app. You can change this later in [Settings → Privacy & Security → Tracking].
• Advertisements are still displayed even if you stop tracking (they will not be tailored to your interests).
• If the age category calculated from your year and month of birth is under 18 (or no year and month of birth has been entered), we configure the ad SDK to serve ads that do not use the advertising ID (not tailored to your interests).

8. Minors

• Persons under 13 may not use the Service. If under 13 is entered at first launch, we do not connect to our server and do not store the year and month of birth. If we learn that information belongs to a person under 13, we delete it.
• At first launch we ask for your year and month of birth, calculate an age category and use it for the monthly purchase limit for users under 18 (13 to under 16: 5,000 JPY / 16 to under 18: 20,000 JPY; purchases exceeding the limit cannot be made) and for age-appropriate advertising settings.
• If you are a minor, please read this Policy together with a parent or guardian and obtain their consent before use.

9. Retention Periods

10. Security Measures

We take the following measures to prevent leakage, loss or damage of personal data.

• Organizational: we designate a person responsible for handling, and record the reason and person for each operation of the administration tools.
• Personnel: we ensure that those who handle data maintain confidentiality and handle it appropriately.
• Physical and technical: server data is protected by access controls so that it cannot be rewritten directly from users' devices, and administration tools can be used only by authorized persons. Device identifiers and IP addresses are hashed when used for fraud prevention.
• Understanding the external environment: because we may store and process personal data in the United States, we take security measures with an understanding of the United States' personal information protection system.

11. Requests for Disclosure, Correction, Suspension of Use, etc.

You may request disclosure, correction, addition, deletion, suspension of use, erasure, suspension of provision to third parties, and disclosure of records of provision to third parties regarding your personal data held by us. Please contact the contact point in Section 12. To verify your identity we will ask for your user ID (shown on the settings screen) and similar information. The fee is [free / [ ] JPY per request].

• You can also delete your account by the following methods.
  • In the app: [Settings → Delete account]
  • The web account deletion page (URL: [ ]). You can use it after deleting the app or when your device is not at hand. Sign in with the Google (Play Games) or Apple account linked in the app; after verifying your identity and a confirmation screen, the account is deleted immediately. Sign-in information is used only to verify your identity and is not stored.
  • If you use the Service without linking a Google or Apple account and the app is on your device, use [Settings → Delete account] in the app. If you have deleted the app or your device is not at hand, no one can log in to that account and it is erased automatically one year after the last use (one year and 30 days if you have ever purchased a paid item) (Section 9). If you wish to delete it sooner, contact the contact point in Section 12. We delete it to the extent we can verify your identity, for example by user ID (if known).
• When you delete your account, game data is erased within the periods in Section 9. Scores for the current ranking period are removed from the leaderboard. Trading records, fraud-prevention information and purchase records are kept in de-identified form for the periods in Section 9.

12. Contact

• Operator: 野田晶裕
• Address: provided promptly by e-mail upon request (same treatment as in the Notice under the Act on Specified Commercial Transactions)
• Representative: 野田晶裕
• Contact (e-mail): tomorinoshima.game@outlook.com

13. Revisions

We may revise this Policy to reflect changes in laws or the Service. Important changes are announced through in-Service notices, and we may present the revised Policy at startup of the Service and ask for renewed consent.

Language

This Policy is written in Japanese. Translations into other languages are provided for reference only; in case of any discrepancy, the Japanese text prevails.

Established on [date]

Back to index