Privacy Policy

Akatsuki Taiwan Inc. (may be referred to hereafter as “we” or the “Company”) endeavors to protect the personal data and privacy of our users. To that end, we have established this Privacy Policy (the “Policy”) for collection, processing and use of personal data in relation to your downloading and use of [Within] (the “Game”). You are advised to carefully read this Policy before commencing use of the Game, and by using the Game, you agree to this Policy as follows:

1. Purpose of Data Collection
    To provide the services and optimize user experience of the Game, we will collect data in accordance with this Policy. All User Data (defined in Clause 2 hereafter) obtained through providing the services of the Game will be used in accordance with the applicable laws within the scope of the following purposes:
  • a. Consumer and client management and services
  • b. Investigation, statistics collection and research analysis
    Notwithstanding the foregoing, any Clause of this Policy or the Policy taken as a whole shall not be interpreted as limitation to the Company to use the User Data outside the scope of the above-mentioned purposes to the extent permitted by the applicable laws.
2. Data Content & Categories
    We will collect the following data (the “User Data”) from the users of the Game (the “Users” or “you”) pursuant to this Policy:
  • a. Data that can be used to identify a natural person : identifiers of a User’s terminal device collected through Unity Analytics and Facebook SDK.
  • b. User’s location information, including the country and city where you are located.
  • c. User’s click information.
    If you by turning off relevant functions or any other way ceases provision or request deletion of the above-mentioned data, your access to the Game may be limited or entirely terminated.
3. Data Protection Measures & Outsourced Processing
  • a. We will protect the persona data collected pursuant to this Policy by adopting technologies and procedures of the level reasonably expected in the same industry (including but not limited to applying restriction to access of the User Data and using relevant data safeguarding software). We may provide the User Data partially or wholly to a third-party service provider for processing. In that case, we will enter into a confidential agreement based on this Policy with such service provider in advance, and undertake necessary and reasonable supervision, so to procure the service provider to adequately safeguard the User Data.
  • b. The Company has designated the chairman of the Company as the officer in charge of the management of the User Data, and will maintain and continue to improve the management of the User Data.
4. Period, Territory, Audience and Methods of Use of User Data
    Our use of your User Data commencing from your downloading the Game, up until you delete the Game from your terminal device or request cease of use thereof. The User Data will be used in all territories outside China. The User Data may be used on all Users, by way of marketing the Game, gathering statistics of and analyzing users’ behaviors to improve and develop the Game, and selecting and providing advertisements to the Users. With respect to the use of the User Data of the Users located in the European Union, please refer to Clause 10 “For European Union Users Only”.
5. With respect to your User Data, you may exercise the following rights in accordance with the Personal Information Protection Act of Taiwan:
  • a. To inquire or request to review the User Data.
  • b. To request a duplicate of the User Data.
  • c. To request supplementation or correction of the User Data.
  • d. To request cease of collection, processing or use of the User Data.
  • e. To request deletion of the User Data.
6. To provide the services of the Game to you, we may, after obtaining your consent, to provide to your User Data to our cooperation partners, which may include your User Data.
7. International Transmittance
    Based on the purposes provided in Clause 1 of the Policy, your User Data may be transmitted to a country/area outside the country/area where you are located , including countries/areas with personal data protection of a level lower than the country/area where you are located. In such case, we will adopt adequate protection measures to protect the personal data provided by you.
8. If this Policy is modified in the future due to legal requirements, operation needs or any other reasons, such modification will be announced and publicized in the Game or on our company’s official website. By continuing your use of the Game, you agree to accept such modification. If you do not agree to accept any modification to this Policy, you may stop using the Game.
9. For European Union Users Only
    We retain the User Data as long as needed to provide services or products to you, or as required or permitted by applicable laws. If you make a request for erasure of your User Data in accordance with the preceding Paragraph, and we determine that there is a valid basis for your request, we will inform you of the time to erase your User Data.
  • a. This Clause is applicable to Users located in the European Union only. In the case that you are located within the European Union, this Clause takes precedence over any inconsistent Clauses in the remainder of this Policy.
  • b. Request to erase User Data
    In the case of the following situations, you may request us to erase your User Data by providing reason(s) in detail, but given the operation model of the Game, we may not be able to provide the same services after such erasure:
      i. You believe that your User Data is being unlawfully processed by us.
      ii. You believe that there is no necessity for us to collect your User Data.
      iii. You wishe to withdraw your consent to our processing and use of your User Data.
  • c. Retention of User Data
    We retain the User Data as long as needed to provide services or products to you, or as required or permitted by applicable laws. If you make a request for erasure of your User Data in accordance with the preceding Paragraph, and we determine that there is a valid basis for your request, we will inform you of the time to erase your User Data.
  • d. Data Portability
    You have the right to obtain from us the User Data that you have previously provided to us, in a structured, commonly used and machine-readable format and a right to request that we transfer such User Data to third party designated by you. If you wish for us to transfer the User Data to any third party designated by you, please ensure you inform of the third party that we can only do so where it is technically feasible. We are not responsible for the security of the User Data or its processing once received by the third party.
  • e. Objection to Profiling & Target Marketing
    You have the right to object to our building profiles of your User Data. Please provide as much detail as possible on your reasons for the request, and upon confirming that you have a valid basis for objection, we will stop building profiles of your User Data unless otherwise provided by the applicable law. However, given the operation model of the Game, we may not provide the same services after you object to our building profiles of your User Data.
  • f. Right to Restrict Processing
    Under the following circumstances, you may request us to restrict the processing of your User Data:
      i. Upon deleting your User Data, you wish for us to preserve your User Data.
      ii. You have doubt in respect of the correctness of your User Data, and we are in the process of confirming the correctness thereof.
      iii. We no longer need your User Data, but you request us to restrict processing thereof for exercise or defense of your legal rights.
  • g. Transfer Your User Data Outside European Union
    Your User Data may be transferred outside of the European Union. We will take adequate steps to ensure that recipients of your User Data are bound to duties of confidentiality and we implement measures such as appropriate contractual clauses to ensure that the recipients of such transfer protect and treat your User Data in accordance with all applicable personal data protection laws.
  • h. Data of Children
    The Game is not intended for children under the age of 16 who are located in the European Union. We do not knowingly collect or maintain any personal data from anyone under the age of 16 who is located in the European Union. We will delete any personal data we believe that was submitted by any child under the age of 16 who is located in the European Union.
10. If you have any question regarding this Policy, please kindly contact us at [official.within@gmail.com]
11. The last modification date of this Policy is [2019/8/14].