Privacy Policy, in human words:
We collect only what we need to make the game work well, like gameplay stats, bug info, and voice/text chats for features and safety. Your data stays private and is never sold. You can ask us anytime what we have, or choose to limit what’s shared.
Preface
Bergamot Games Inc. ("We") believes that protecting personal information is a social responsibility of Internet business operators. We will properly handle our customers’ ("You") personal information pursuant to our Privacy Policy and Compliance Program for the Protection of Personal Information.
In order to ensure that you feel secure and comfortable using our Internet services ("Services"), we will operate and manage our Internet services in accordance with our Internet Services Privacy Policy, as stated below.
This Privacy Policy applies when we use or obtain your personal information through the Services that we operate and manage. However, if any different terms are noted when you provide your personal information, then those terms will take precedence over this Privacy Policy.
If you do not wish us to obtain your personal information, then you can refuse at your own discretion. You may withdraw your consent about this Privacy Policy at any time. In these case, you may not be able to use the Services.
As used in this Privacy Policy, the term "personal information" refers to information that can be used to determine your identity or is unique to you, such as your name, address, telephone number, email address, and month and year of birth. In addition, we may handle advertising IDs, cookies, user IDs, IP addresses, product purchase histories, and other identifiers not tied to your personal information (hereinafter referred to as "Personally Referable Information". personal information and Personally Referable Information are collectively referred to as "Personal Information"). When handling such information, we will take necessary measures, such as obtaining the consent from you, in accordance with the provisions of laws and regulations, and when we receive personal information from a third party and link it with obtained your personal information, we will handle it in accordance with Purpose of use of Personal Information.
We will use Personal Information obtained from you for the following purposes, relying on your acceptance of this Privacy Policy.
(1) Age verification for purposes of protecting minors
(2) Registration of information about you, and identification of you
(3) Customer support, and responses to inquiries
(4) Applications for free goods and other campaigns
(5) Shipment of products you have purchased or free goods you have won
(6) Provision of information about the Services, such as push notifications and email newsletters
(7) Payment of Services fees
(1) Improvement of the Services, products, etc. and development of new services and products
(2) Customization of contents and advertisements presented to you while you are using the Services, according to your registered information, use records, and other criteria
(3) Research and questionnaire surveys on the Services to know, for example, how much you are satisfied with the services, products, etc. you have ordered
(4) Understanding of the advertising distribution status, measurement of the effect of advertising, and presentation of behavioral targeting advertising
Please note that the analysis results that we will provide to third parties do not include information from which your identity can be determined.
(5) Identify and resolve the cause of the failure or problem that occurred in the Services.
(6) Model quality, safety, and anti-fraud activities, including detection of spam, harassment, prohibited content, cheating, or exploits in text and voice features and related accounts, and application of rate-limits or access controls when necessary.
Outsourcing the handling of personal information to our collaborators, alliance partners, and outsourcing contractors, all of which have signed confidentiality agreements with us about the handling of personal information, to the extent necessary for achieving the purposes of use presented to you
(1) Announcement of other services we will provide
(2) Requests for your cooperation in our questionnaire surveys and invitations to events and seminars, and reporting of the results of those surveys and the like
Sending of information about us, questionnaires, or third-party advertisements or similar material that you may find useful
For individual services, we may use your personal information for purposes not stated above. In such a case, we will obtain your consent in advance.
The personal information and Personally Referable Information we will obtain from you is as follows. In addition, we may handle the following Personally Referable Information provided by a third party with linking to personal information obtained from you.
Information directly obtained from you (or provided by you)
The information you will provide when using the Services will be obtained by us. This includes all information about yourself that you will directly provide in connection with the Services, such as your name, user name or nickname, email address, password and other pertinent information for your account, and feedback and inquiries.
Terminal information (automatically obtained)
When you use the Services on your stationary or portable terminal, we will obtain the terminal identifier (including but not limited to advertising ID generated by OS), the portable terminal identifier and the IP address. We will also obtain all other information you elect to provide, such as the name, terminal type, telephone number, country, user name or email address you have associated with your terminal.
Geolocation information (automatically obtained)
If you agree to provide geolocation information when using the Services on your stationary or portable terminal, we will obtain information about your current location.
Payment information (automatically obtained)
If you purchase virtual currencies or other gifts within the Services or purchase a license to use virtual items directly from us, we will obtain the necessary information for payment processing, such as your address and email address. If your purchases are processed through third-party payment services (including, but not limited to, those provided by Apple Inc. and Google Inc.), we may obtain the billing and payment information you provide to the payment services company.
Information about customer support (automatically obtained)
If you receive support from our customer support team, your contact information (including, but not limited to, your name and email address) provided by you, information about your service-related activities, and your user ID number may be obtained and retained by us. We may also obtain and retain records of your communications with our support team and information contained in such communications.
Communication information (automatically obtained)
If you communicate with any other user of the Services, or with game systems, participate in certain information sharing activities in connection with the Services, then we may obtain and retain archives of information about such communications.
Gameplay analytics (automatically obtained)
When you use the game, we collect gameplay analytics. This may include pseudonymous identifiers, interaction and progression telemetry, timing/latency and network quality indicators, and aggregate virtual currency usage.
Voice and chat processing (automatically obtained)
If you use voice features, your microphone audio is processed to enable speech-to-text and in-game responses. We may retain raw audio for troubleshooting and safety review for a limited period, and transcripts and in-game replies to improve conversation quality, provide player-visible summaries or diaries, resolve support requests, and investigate safety or abuse reports. We instruct service providers handling voice/text processing to use data only to provide services to us. Automated and human review may be used to detect prohibited content or safety risks. Avoid including personal information (e.g., full names, addresses, payment details) in chats between players and with LLM. If you do, we may redact or delete such information where technically feasible, but removal from all logs cannot be guaranteed.
Information about your third-party service accounts (automatically obtained)
If you link any of your third-party services to the Services, we will obtain information about your third-party service account, such as your login identity.
Cookies (automatically obtained)
We may use cookies (including similar technologies) when you are using the Services through a web browser. Cookies are small data files downloaded to your information terminal that are used to ensure the safe and smooth operation of the features of the Services and for us to obtain information about your desired settings. Web browsers can be configured to disable cookies. But, please note that if cookies are disabled, some of the features of the Services may not work normally.
Information about your usage of Services (automatically obtained)
We may obtain your purchase history or usage history of products and services in the Services may by linking them with identifiers such as terminal identifier or cookies and so on.
Personal information provided by you will not be disclosed to third parties without your consent, except when
(1) the information is processed into statistical data form from which your identity cannot be determined;
(2) the provision of the information is required by laws, regulations, or the like;
(3) such disclosure is necessary for protecting a person's life, body, or property, and your consent is difficult to obtain;
(4) such disclosure is especially necessary for improving public health or promoting the healthy development of children, and your consent is difficult to obtain; or
(5) we are required to cooperate with a national government agency or local government, or its assignee in the execution of statutory affairs, and obtaining your consent would be detrimental to the execution of such affairs.
Personal Information being provided by you will be secured and protected against unauthorized access by third parties, using encryption with SSL (Secure Sockets Layer) or other similar security techniques. Once provided, your Personal Information will be placed under strict control to protect against loss, destruction, alteration, leak, and other such risks. In addition, when personal information is handled by an entrusted company (including foreign country), we will take safety management measures under appropriate supervision.
If accident such as leak of personal information has occurred, we will respond appropriately, such as by reporting it in accordance with the provisions of laws and regulations.
We may transfer the obtained Personal Information not only to the countries or regions designated by the Personal Information Protection Committee that are expected to protect personal information equivalent to that of our country (such as the United Kingdom and the EEA region) but also the other countries. In this case, we will ensure the system for obtaining the consent from you or continuing the implementation of the corresponding measures in accordance with the provisions of laws and regulations, and appropriately provide the information to you.
In order to achieve the purposes of use, we may transfer to handle personal information about our customers located in the EU and EEA regions to countries outside these regions. Some countries outside the EU and EEA regions may not recognize the same data protection rights as those stipulated by the GDPR (General Data Protection Regulation); however, we will procure sufficient protection for the personal information by concluding standard contracts based on the GDPR, or otherwise.
If you have any questions regarding the transfer of information to third parties in foreign country, please contact us using Contact information.
If you wish to access, rectify, or erase (including the erasure due to the withdrawal of consent) Personal Information you have provided, then please use the personal information access/rectification/erasure features available, or contact the support center described in Contact information. The requested access, rectify, or erasure or the like will be effected within a reasonable period of time after we have confirmed that the request was made by you and not someone else.
We will retain your Personal Information as long as required in order to provide you with our Services or achievement of other purposes of use; however, we will delete it promptly and completely after it becomes unnecessary. We will not retain such Personal Information in any form, such as backup copies.
We will also use utmost care to protect information about customers under 18 years of age. We request that personal information about customers under 18 years of age not be provided without their guardians' consent.
We will not be responsible for the handling of Personal Information on websites of third-party business operators or individuals linked to our Services.
We will comply with laws and regulations and other rules relevant to the protection of personal information.
We may revise this Privacy Policy in response to revisions of laws or regulations or the like as they happen.
You may submit legally permitted inquiries about your Personal Information to the following contact center. In addition, if you are located in a country of the European Union and if you have any questions about your Personal Information or if you want to exercise any of your rights under GDPR, you can also contact us:
Bergamot Games Inc.
Email: info@bergamotgames.com
July 21, 2024
Bergamot Games Inc.
