This Summary Privacy Policy ("Summary") explains how we, Aniplex Inc. (4-5 Rokubancho, Chiyoda-ku, Tokyo, 102-8353 Japan) (“Aniplex”) and any legal entities controlled (the term “control” in this context means the direct or indirect ownership of at least fifty percent (50%) of the voting interest in such corporation or the power in fact to control the management decisions of such entity) by Aniplex (“We”, "Us" and "Our") collect, use, disclose and/or store information or data of any kind (e.g., email address, username etc.) about or related to you, even if such information cannot directly identify you on its own but can be used in combination with other information that is stored by Us ("Personal Data") in connection with Our website https://rpgtime-en.com/ for the “RPG Time: The Legend of Wright” (the “Product”) whether accessed via computer, mobile device or other technology (the “Site”). It also describes your data protection rights, including your right to object to some of the processing which We carry out. More information about your rights, and how to exercise them, is set out in the Full Privacy Policy below.

1. Scope of Applicability

This Summary and the Full Privacy Policy (together the ("Privacy Policy") apply to you if you use the Site.

2. Processing of your Personal Data

We collect and use the following Personal Data related to your use of the Site:

• a.Information you provide to Us, such as information on the inquiry form, e.g., your email address, username, or contents of the inquiry.
• b.Information that We collect automatically (as the case may be, subject to your consent), such as your IP address or other identifiers for the device you use to access the Site, technologies such as Cookies or Web Beacons. You can either allow or refuse Us to set and use Cookies and similar technologies by setting your preference on the Cookie Preference Center.
• c.Information We receive from third parties, e.g., service providers that work on Our behalf, which may provide Us with information that is necessary to validate your transaction. Further, We may receive information on how you use the Site or third party websites from third party analytics service providers, ad network providers or social media applications that We make use of and which may process certain Personal Data about you subject to their privacy policies and/or terms of use.

3. Processing Purposes

We collect and use your Personal Data related to your use of the Site (collectively, the "Collected Data") to provide you with features and functions of the Site, to respond to your inquiry about the Product and to provide you with other requested content related to Our services and other offerings.

4. Legal Justifications for the Processing of the Collected Data

One of the key privacy law requirements is that any processing of Personal Data has to have a legal justification. We generally use the following legal justifications: the Processing is necessary for (i) the performance of a contract, (ii) compliance with a legal obligation, (iii) realizing a legitimate interest, and, (iv) if you have provided your prior consent, we also rely on such consent.

5. Data transfers and Recipients including International Data Transfers

In accordance with applicable law, We transfer your Personal Data to Our service providers, third parties (e.g., third party service providers, business partners such as customer service provider and traffic measurement service provider), and, as the case may be, governmental authorities, courts, external advisors, and similar third parties. Some of the aforementioned recipients are located in jurisdictions outside the European Union / European Economic Area (jointly the "EU") and United Kingdom such as the United States, Japan, and/or other jurisdictions that may not provide the same level of data protection as your home country/region.

6. Retention periods for and deletion of Collected Data

Collected Data will generally be deleted once they are no longer needed for the purposes motivating their original collection or as required by applicable law.

7. Children’s Privacy

We do not knowingly seek or collect personal information from or about children without the consent of a parent or guardian.
Any parent or guardian with inquiries regarding our processing of personal information relating to their child should contact Us at https://rpgtime.jp/contact/

8. Your statutory rights

As set forth by applicable law, you have certain rights with regard to the Processing or your Personal Data, each as per the conditions defined in applicable law, such as the right to get access to your data, to get them corrected, erased or handed over. Please refer any of your questions to https://rpgtime.jp/contact/

9. Changes to this Privacy Policy

From time to time, We may have to update this Privacy Policy. We will let you know of any material changes to this Privacy Policy through the Site.

10. Contact Information and how to contact Us

If you wish to exercise your data subject rights, have a privacy concern, complaint or any other question how we process Personal Data, please contact Us by mail or email:
Name: Aniplex Inc.
Address: 4-5 Rokubancho, Chiyoda-ku, Tokyo, 102-8353 Japan
email: https://rpgtime.jp/contact/

1. Processing of your Personal Data

We process the following Personal Data related to your use of the Site:

• a. Personal Data you provide to Us:
  When you contact Our customer service center for assistance, We may keep information about the contents of the inquiry, including your email address, username, the reason why you contacted Us and the answer We gave you.
• b. Personal Data We collect by technical means:
  In addition to any information that you choose to provide to the Site, whenever you visit or interact with the Site, We, as well as any third-party analytics providers or other service providers, may use a variety of technologies that automatically or passively collect information about how the Site is accessed and used, including but not limited to, browser type, operating system, the page served, time on the Site, and the preceding page views, which might be qualified as Personal Data ("Usage Information"). We may also automatically collect your IP address or other unique identifiers ("Device Identifiers") for the computer, mobile device, technology or other device (collectively, "Devices") you use to access the Site. A Device Identifier is a number that is automatically assigned to your Device when you access a property or its servers, and Our computers identify your Device by its Device Identifier. Some mobile service providers may also provide Us or Our third-party service providers with information regarding the physical location of the Device used to access the Site. The technologies used on the Site to collect Usage Information, including Device Identifiers, include:
  
  
  • • Cookies, which may be html files, Flash files or other technology, are small text files that help store user preferences and activity ("Cookies"). A Cookie is placed on a Device when that Device is used to access or visit the Site. Cookies may be used for many purposes, such as remembering you and your preferences, tracking your visits to the Site and customizing your experience on the Site. You may configure your browser or Device to block the use of certain cookies. However, please note that if you choose to disable cookies on your Device, some features of the Site and Our online offerings may not function properly.
  • • Web Beacons, also known as image tags, pixel tags, clear GIFS or web bugs, are small pieces of code used to collect advertising data, such as counting page views, promotion views or advertising responses (“Web Beacons”). Web Beacons or similar technologies may be used for various purposes, including, without limitation, to count visitors to the Site, to monitor how users navigate the Site, to count how many sent emails were actually opened or to determine whether content sent was actually viewed.
  • • Embedded Scripts: An embedded script is programming code that is designed to collect information about your interactions with the Site, such as the links you click on. The code is temporarily downloaded onto your Device from Our server or a third-party service provider, is active only while you are connected to the Site, and is deactivated or deleted thereafter.
  • • Ad Serving and Traffic Measurement Services
    We license technology to serve advertisements on the Site and within its videos and other content as that content is served across the Internet. In addition, We may use third party network advertisers to serve advertisements on the Site and third-party analytics service providers (such as Google Analytics https://www.google.com/intl/ja/policies/privacy/partners/) to evaluate and provide Us with information about the use of the Site and viewing of Our content. We do not share the information that you provide to Us, such as your name and/or email address with these third parties, but ad network providers, the advertisers, the sponsors, and/or analytics service providers may set and access their own cookies, web beacons and embedded scripts on your Device from the Site. These cookies, web beacons, and embedded scripts may collect personal information or other information about your use of the Site over time and other third-party websites or applications and they may otherwise collect or have access to information about you, including Usage Information. Cookies and web beacons, including those set by third party network advertisers, may be used to, among other things, target advertisements, prevent you from seeing the same advertisements too many times, or conduct research regarding the usefulness of certain advertisements to you.
  
  Please note that third parties may collect personal information about your online activities over time and across different websites when you visit or use the Site or other online websites and services. For example, some third parties' embedded content or plugins on the Site, such as social media sharing tools, allow their operators to learn that you have visited or interacted with the Site, and they may combine this information with other, identifiable information they have collected about your visits to other websites or online services. These third parties may handle this information, and other information they directly collect through their content and plugins, pursuant to their own privacy policies.
  Online Tracking. Some web browsers incorporate a “Do Not Track” feature that signals to websites that you visit that you do not want to have your online activity tracked. How browsers communicate the Do Not Track signal is not yet uniform. For this reason, the Site do not respond to such signals, except where required by law.
  Cookie Management Tool. You can either allow or refuse Us to set and use Cookies and similar technologies by setting your preference on the Cookie Preference Center.
• c. Personal Data We Receive from Third Parties
  
  • (1) Service providers acting on Our behalf:
    We may receive Personal Data about you from service providers working on Our behalf. In addition, if you use another property and you opt-in to receive information from Us, that property may forward to Us your email address and other Personal Data so that We may contact you as requested. We may also supplement the Collected Data with outside records from third parties to enhance Our ability to serve you, to tailor Our content to you and to offer you opportunities to purchase products, contents or services that We believe may be of interest to you. We may combine the Personal Data We receive from these third parties with Collected Data. In those cases, We will apply this Privacy Policy to any Personal Data received, unless We have disclosed otherwise.
  • (2) Social Media Applications:
    Functionality on the Site may permit interactions between the Site and third-party properties, such as Facebook and Twitter. Such functionality enables you to “like” a product or online content, “share” content to other properties, and otherwise link the Site with another third-party property. If you choose to “like” or “share” content or to otherwise post information from or via the Site to a third-party property, that information may become public and the third-party property may have access to your Personal Data and information regarding your use of the Site. You may also choose to participate in a third-party application or feature (such as Facebook applications or a similar application or feature on a third-party property, or otherwise linking the Site with another property) through which you allow Us to collect (or the third party to share) your Personal Data. When you choose to participate, you may be opting to link your activity on the Site with that third-party property, which may then collect information about your visits to the Site and may publish that activity as you request to your "profile" or similar feature with that third party (such as if you choose to share content you find on one of the Site with your "connections" on the third party's property). The Personal Data We collect is subject to this Privacy Policy. However, the Personal Data collected and stored by the third party remains subject to the third party's privacy practices, including whether the third party continues to share information with Us or with other third parties, the types of information shared, and your choices regarding what is visible to others on that third party's property. The third party may allow you to remove an application or feature, in which case We will no longer collect Personal Data about you through the application or feature, but We may retain the Personal Data previously collected in accordance with this Privacy Policy.

2. Processing Purposes

We will use the Collected Data for the following purposes:

• a.Service Provision: We use the Collected Data to operate, maintain, enhance and provide features and functions of the Site.
• b.Communications: We use the Collected Data to communicate with you about the Product and the Site for administrative and informational purposes. Examples of said communications include responses to your inquiries or requests, customer support-related communications and changes to any of Our terms & conditions or policies.
• c.User Experience: We use the Collected Data to personalize your experience on the Site by providing you with tailored information of products, contents and services, as well as recommendations, advertisements, promotions, or offerings that may be of interest to you.
• d.Service Improvement and Development: We use the Collected Data to optimize and improve Our services and products, including the Product and the Site, and to develop new products, contents, services, features and functions by analyzing and understanding the usage trends and preferences of Our users.
• e.Compliance with Law: We use the Collected Data to ensure compliance with Our internal policies, agreements with Our stakeholders, applicable laws and regulations, court orders, government and law enforcement requests. We also use the Collected Data to enforce or defend Our legal rights or the terms and conditions of any Our service, or to retain and store your personal information to comply with specific legal retention requirements, regulatory audits, and other record keeping purposes (including to meet internal and external audit requirements).
• f.Fraud prevention and investigation: We will use the Collected Data to comply with monitoring, prevention, detection and investigation obligations, laws associated with the identification and reporting of illegal and illicit activity, including fraud and anti-money laundering, and financial reporting obligations.
• g.Security: We will use the Collected Data to maintain the integrity and security of Our websites, contents and services and preventing and detecting security threats, fraud or other criminal or malicious activity that might compromise your devices.
• h.Other: In any other way, with your consent or permitted under applicable law.

3. Legal Justifications of the Processing of your Personal Data

For the purpose of this Privacy Policy, “EU” includes the United Kingdom, even though the United Kingdom has left the EEA following Brexit, and, where applicable, Switzerland. We rely on the following legal bases for processing the Collected Data.:

• a.Performance of Contract: We use the Collected Data to provide you with the Site. For example, We use your email address to response to your inquiries or requests on the Site. Such use is necessary for the performance of the contract between you and Us.
• b.Legitimate Interest: We, or a third party, have legitimate interest in using the Collected Data. In particular, We have a legitimate interest in using the Collected Data to improve and develop Our products, contents and services, to personalize your experience on the Site and provide you with tailored information of products, contents and services, and improve the safety, security, and performance of the Site. When We process the Collected Data for Our legitimate interests, We make sure to consider and balance any potential impact on you, and your interests, rights and freedom under any applicable laws. We will not use the Collected Data for any processing where Our interests are overridden by the impact on you, unless We have your consent for Our processing, or otherwise required by law. You have the right to object to processing that is based on Our legitimate interests, as indicated in Section 8 below.
• c.Legal Obligation: We have a legal obligation under applicable law to use the Collected Data, such as the obligation to monitor, prevent, detect and investigate illegal and illicit activity, including fraud and anti-money laundering, and the obligation to provide financial reporting.
• d.Consent: If you have provided your prior consent, We may send you information by email or through other electronic communications on Our products, contents and services, or other promotions, etc. Where Our processing is made based on your consent, you have the right to withdraw your consent at any time, as indicated in Section 8 below. For example, where you give Us consent to place cookies and to use similar technologies, you will be able to opt-out of those materials in accordance with the instructions made in Our communication.

The table below summarizes the Personal Data processed for the respective purposes as well as the applicable legal basis.

4. Data transfers and recipients and legal justification for such transfers

We will make the Collected Data available to third parties as follows:

• a.(Third-Party) Service providers
  We may use service providers to process the Collected Data, some of which may be internal (i.e., part of Aniplex) or external (third party) service providers. In any case, the service providers are engaged for the purposes of pursuing the activities outlined in this Privacy Policy. Some of the service providers are acting on our behalf as data processors. However, we may also transfer to other third party service providers acting as independent controllers (e.g., lawyers, accountants, auditors, etc.).
• b.Business transfer
  In the event that We sell or transfer a portion or all of Our business, Collected Data may be transferred by Us to the purchasing or acquiring entity as part of the transaction. We will continue to ensure the confidentiality of the Collected Data before such transaction occurs, and after such transaction, We will delete the Collected Data as soon as reasonably practicable after such transaction.
• c.Compliance and enforcement
  We will retain, use and/or disclose any of Collected Data as required or permitted by law, regulation or order, including to the police or other appropriate authorities, to investigate complaints made by or against you, or to protect or defend ourselves, or others, against illegal, criminal or harmful activities.

5. International Transfer of the Collected Data

Collected Data will be processed, stored and transferred for the purposes outlined in this Privacy Policy from your country/region of residence to various countries/regions outside your country/region of residence, including Japan and the US. Collected Data will be processed by staff operating outside your country/region of residence who work for Us or for one of Our service providers and may be disclosed to such staff in those countries/regions. We take appropriate measures to ensure that all transfers of the Collected Data from the EU to countries/regions outside the EU meet the requirements of applicable EU and UK data protection legislation and to ensure that appropriate technical and organizational security measures are in place to protect Personal Data against accidental or unlawful destruction, accidental loss or alteration, unauthorized disclosure or access, and against all other unlawful forms of processing. Where information is transferred outside the EU, and where this is to a stakeholder or vendor in a country/region that is not subject to an adequacy decision by the EU Commission or adequacy regulations under the UK GDPR (i.e., a country/region that does not provide the same level of data protection as your country/region of residence), data is adequately protected by EU Commission approved standard contractual clauses, or a vendor's Processor Binding Corporate Rules. Any onward transfer is subject to appropriate onward transfer requirements as required by applicable law. Nonetheless, this may impact your data subjects rights in your local jurisdiction and also in the applicable overseas jurisdiction(s). These overseas jurisdictions may also need to disclose your personal information to a third party, e.g., an overseas authority. If you have any questions or concerns about Our data transfer arrangements, please contact Us (see I. 10. above).

6. Retention periods for and deletion of Collected Data

We will only retain your personal information for as long as is reasonably necessary for the various purposes set out in this policy or to otherwise comply with any applicable laws and regulations concerning the mandatory retention of certain types of information. Where We no longer require the Collected Data, it will be destroyed or de-identified in line with Our policies. When We say de-identified, We mean that We will remove information that could be used to identify you from the Collected Data.

7. Children’s privacy

We consider a child to be anyone under the age of 16. We do not knowingly seek or collect personal information from or about children without the consent of a parent or guardian. If you are a parent or guardian and are concerned that your child has provided Us with personal information without your consent, you should contact Us as indicated in Section II. 1 above. If We become aware that We have received or collected personal information about a child under the age of 16, We will delete that personal information as soon as possible.

8. Your statutory rights

Under the conditions set out under applicable law, you have the following rights:

• a.Right of access: You have the right to obtain from Us confirmation as to whether or not Personal Data concerning you is being processed, and, where that is the case, to request access to the Personal Data. The access information includes – inter alia – the purposes of the processing, the categories of Personal Data concerned, and the recipients or categories of recipients to whom the Personal Data have been or will be disclosed.
• b.You have the right to obtain a copy of the Personal Data undergoing processing. For additional copies requested by you, We may charge a reasonable fee based on administrative costs.
• c.Right to rectification: You have the right to obtain from Us the rectification of inaccurate Personal Data concerning you. Depending on the purposes of the processing, you have the right to have incomplete Personal Data completed, including by means of providing a supplementary statement.
• d.Right to erasure (right to be forgotten): You have the right to ask Us to erase your Personal Data.
• e.Right to restriction of processing: You have the right to request the restriction of processing your Personal Data. In this case, the respective data will be marked and may only be processed by Us for certain purposes.
• f.Right to data portability: You have the right to receive the Personal Data concerning you which you have provided to Us in a structured, commonly used and machine-readable format and you have the right to transmit those Personal Data to another entity without hindrance from Us.
• g.Right to object:
  You have the right to object, on grounds relating to your particular situation, at any time to the processing of your Personal Data by Us and We can be required to no longer process your Personal Data. If you have a right to object and you exercise this right, your Personal Data will no longer be processed for such purposes by Us. Exercising this right will not incur any costs. Such a right to object may not exist, in particular, if the processing of your Personal Data is necessary to take steps prior to entering into a contract or to perform a contract already concluded.

[Notice to California Residents]

CA Personal Information. Consistent with Section II. 1 above, We collect certain categories of Personal Information about California residents (“CA Personal Information”) for the purpose described in this Privacy Policy, specifically: Identifiers, Commercial Information, Internet or Other Electronic Network Activity and Audio, Visual and Similar Electronic Information.

California Consumer Rights.
Subject to certain exceptions detailed in the California Consumer Privacy Act, as amended by the California Privacy Rights Act (“CCPA/CPRA”) and other applicable laws and regulations, as a California resident, you have the right to:

• •request access to your CA Personal Information, including information about the categories of CA Personal Information We have collected, the categories of sources from which We have collected your CA Personal Information, the business or commercial purpose for collecting, selling, or sharing your CA Personal Information, the categories of third parties to whom We disclose CA Personal Information, and the specific pieces of CA Personal Information We have collected about you;
• •request deletion of your CA Personal Information; however, to the extent permitted by applicable law, We may be required to retain some of your CA Personal Information, and certain CA Personal Information is strictly necessary for Us to fulfill the purposes described in this Privacy Policy;
• •if We maintain any inaccurate information about you, request correction of that inaccurate CA Personal Information;
• •for sensitive CA Personal Information that We collect, request that We limit our use of your sensitive CA Personal Information to that use which is necessary to perform the services or provide the goods reasonably expected by an average consumer who requests such goods or services and as otherwise authorized under applicable laws;
• •request information about the CA Personal Information about you that We have disclosed for a business purpose and the categories of persons to whom it was disclosed for a business purpose;
• •request information about the CA Personal Information about you that We have "sold" or "shared" (as such terms is defined under applicable California privacy laws) and the categories of third parties to whom the CA Personal Information was sold or shared; and
• •opt-out of the "sale" or "sharing" of your CA Personal Information (as such terms is defined under applicable California laws), if applicable.

Exercising Your California Consumer Rights.
If you are a California resident and wish to exercise any of these rights or if you have questions regarding the CA Personal Information collected or shared with third parties, please: (a) contact us as described in the section I. 10 above with the specific nature of your request, referencing “Your California Privacy Rights”; or (b) submit online on the Site https://rpgtime.jp/contact/. When submitting your request, you must include your first and last name, email address, and zip code or mailing address. You may be asked to provide additional proof of identification so that We can verify your identity and validate the request. Please note that you are limited by law in the number of requests you may submit per year. We will not discriminate against you by offering you different pricing or products, or by providing you with a different level or quality of products, based solely upon you exercising your rights to your CA Personal Information.

Sources of CA Personal Information.
Consistent with Section II . 1 above, we may collect CA Personal Information from you.

Purposes.
We collect the CA Personal Information for the business and commercial purposes described above. We also share your CA Personal Information as follows:

• •Sharing your CA Personal Information for Business Purposes:
  In the preceding twelve months, We may have shared the following categories of CA Personal Information for business purposes: Identifiers and Other Consumer Information. This information may be shared for the purpose of providing services to you, for legal compliance, or to protect legitimate interests, in compliance with law.

Sale of CA Personal Information.
In the preceding twelve (12) months, We have not sold (as defined under CCPA) CA Personal Information. We do not knowingly share the CA Personal Information of individuals under sixteen (16) years of age, in a manner that constitutes a "sale" under California law.

Authorized Agents:
To the extent that you elect to designate an authorized agent to make a request on your behalf, they must provide appropriate documentation including written signed permission from you, proof of your identity, and verification of their identity; or a valid, designated power of attorney as defined under the California Probate Code.

• Please note that the aforementioned rights might be limited under the applicable national data protection law. Please refer any of your questions to https://rpgtime.jp/contact/. In case of complaints, you also have the right to lodge a complaint with the competent supervisory authority.

LAST UPDATED: June 23, 2022