Privacy Policy

Pui Pui Yu (“we,” “us,” or “our”) respects your privacy rights and is committed to being transparent with our use of your information. If you are a resident or access our Services from within the European Economic Area (“EEA”), we apply the privacy protection to your information required by the General Data Protection Regulation.

This Privacy Policy applies to our use of your information throughout the Services, unless a part of the Services is governed by its own privacy policy. Our Services are currently:

  • Our newsletter at https://usagishima.net/newsletter (the “Newsletter”)
  • Our game “Usagi Shima” (the “Game”)

About

This Privacy Policy concerns the information that (i) you may provide us with (for example when you sign up with our Service) and that we may (ii) collect from you automatically when you use our Service, (iii) receive from other, third party sources, or (iv) collect from you because you made this information publicly available (for example public archives).  

We protect and grant you your rights regarding information that can identify you as an individual (for example your name, age, gender, online user name, or your political opinion or religious belief) as well as information that can only personally identify you together with other information that we collect from you (for example your IP address, your activity with our Services, hardware device ID, or your browser type) (“Personal Information”). 

Some of your information may be collected, stored, used, disclosed, or shared, anonymized by isolating the information from any personal identifiers and thereby cannot be used by us, or third parties that we share such information with, to identify you. 

We may store some of your information via local storage (for example cookies) temporarily or permanently on your internet enabled device, which allows us to retrieve information on your device about your use of the Services (e.g. which language you prefer or your login name).

What We Collect and How We Use It

General Use Policy. We may use your information to provide, administer, maintain, and improve our Services; personalize your experience of the Services; analyze user activity of our Services; provide you with support regarding our Services; engage in advertising activity; to enforce our rights and the rights of other users of the Services, and to comply with our legal obligations; or to prevent imminent and serious bodily harm to a person. 

Information You Provide Us With

Our Newsletter. We collect the following Personal Information when you subscribe to our Newsletter to contact you at your email address and update you about our Services: 

  • Email Address

Reaching Out To Us. We collect information from you when you send us or one of our representatives an email or otherwise correspond with us directly (for example your name, email address, or statements that you make). We store this information, including Personal Information, for purposes of reacting to your request and providing you with the necessary support regarding our Services. We will not collect information if your communication with us does not relate to our Services or future services.

Information We Collect Automatically

Automatic Collection. We make use of various third party analytic and reporting technologies and partner with third parties to record information automatically when you use our Service. Currently we employ the following third party services, each of which collects data in accordance with their respective privacy policies:

Playing Our Game. When you play our Game we automatically collect the following information in anonymized form from you to operate and improve the Game, improve your playing experience of our Game, monetize the Game, or provide support to you when the Game crashes:  

  • IP Address
  • Interactions between You and and the Game
  • Diagnostic Information
  • Approximate Location
  • Device Identifiers
  • Crash Logs
  • Stack Traces
  • Analytics Information, such as Session History
  • Country
  • Ad Watching Behavior
  • Game Milestones
  • Purchase Behavior
  • Achievement Data
  • Device Identifiers, such as Advertising ID

Cookies

Cookies. We may also automatically and in the background place small data files on your device that you use to access our Services. These may be cookies, local storage, or trackers, (“Cookies”) and we use these in order for some of our Services to work properly. By default, we use several persistent cookies (permanent or stored cookies) as well as session cookies (transient cookies erased each session). Cookies are used for purposes of authentication, security, preferences, (e.g., regarding default language and settings), connection stability (e.g., for uploading media, using e-Commerce features, etc.), monitoring performance of our services and marketing campaigns (e.g. page visits, currently active visitors, sessions by countries, from which website you accessed our Services), and generally providing and improving our Services. 

Cookies can be separated into essential (or functional and required) Cookies and optional (or analytic and performance) Cookies. At any time, you may prevent our use of any of these by changing the settings in your browser. However, disabling essential Cookies will prevent certain features of our Game from functioning as you expect. 

Google Admob uses cookies or mobile ad identifiers for frequency capping, aggregated ad reporting, and to combat fraud and abuse. You can review the list of cookies at https://business.safety.google/adscookies/.

Unity Ads uses cookies or related technologies within the Game to store information on or read information from your browser or device so that it can show you contextual ads. You can review Unity’s Cookie Policy at https://unity.com/legal/cookie-policy for more information about the cookies used.

How We Share Your Information With Third Parties

Our Sharing Policy. We may share your Personal Information for the purposes described in this Privacy Policy to our subsidiaries or successors and affiliated third parties. We will only share your Personal Information beyond that with your consent or in the following events: to prevent an emergency, to prevent harm to others, to respond to legal requirements, to protect or enforce our rights and policies, to protect or enforce the rights of a third party, or as required or permitted by law (including, without limitation, to comply with a subpoena or court order). We will treat your Personal Information as subject to the protections described in this policy.

We may transfer Personal Information for processing in countries in which the privacy laws may not be as comprehensive as those in the country where you reside or are a citizen. If you have accessed our Service from within the EEA, additional rules apply to the transfer of your Personal Information (see below).

Third Party Service Providers. We contract with third parties who help us with our Services. Currently the third parties are:

  • GameAnalytics: For analytics, improving game stability and experience, and improving marketing.
  • Google Play Services Plugin: For cloud save functionality.
  • Google AdMob: To show ads.
  • Google Play Billing Library: To enable in-app purchases.
  • Apple App Store Plugin: To enable in-app purchases.
  • Unity Ads SDK: To show ads.
  • iCloud: For cloud save functionality.
  • Game Center (Apple): Required to play the Game.
  • The Newsletter Plugin: To provide news and announcements about the Game.

We take commercially reasonable precautions to prevent such third parties from disclosing your Personal Information. Their use of this information is contractually bound to the purposes of this Privacy Policy and their own privacy policy (found on their websites). However, we cannot guarantee that such third parties will not disclose your information. 

How We Protect Your Personal Information

We take reasonable measures to protect the confidentiality, security, and integrity of your information. We have implemented physical, electronic and managerial procedures in order to help safeguard and prevent unauthorized access, use, alteration, modification and/or disclosure of your information by which you can be identified. 

We cannot ensure or warrant perfect security. Accordingly, we assume no liability for any disclosure of data due to errors in transmission, unauthorized third party access or other acts of third parties, or acts or omissions beyond our reasonable control.

Our Policy on Information from Children

Under Eighteen. Our Services are intended for users ages 18 and older only. Accordingly, we will not knowingly collect or use any Personal Information from children that we know to be under the age of 18. In addition, we will delete any information in our possession that we discover originates from a child under the age of 18. 

Parental Controls. If you believe that your child’s Personal Information was mistakenly collected through our services, please contact us immediately at support@usagishima.net and we will work with you to determine if this is the case and remove such information if necessary.

Your Options On How We Treat Your Personal Information

Personal Information. You may review, update, change, or delete your information that can be used to personally identify you, by requesting that we cancel your access to our Services (for example, delete your Game Account) at support@usagishima.net.

Cookies And Local Storage. You may delete local storage or cease our placement and use of local storage by setting your browser or internet enabled device to disable local storage. Please be aware that local storage is important for your access to our Game and if you disable local storage, your access to our Game may be restricted or impossible.

Opting-Out. You may opt-out from having your Personal Information used for certain purposes. If you no longer wish to receive our newsletters, you may opt-out of receiving them by following the instructions included in each newsletter or communication or by emailing us at support@usagishima.net.

Retention. We retain information about you as long as it is necessary for us to fulfill the purposes outlined in this Privacy Policy. In addition, we may retain your information for an additional period as is permitted or required to (for example to comply with our legal obligations, resolve disputes, and enforce agreements). If required by applicable law, we shall delete your information when the information is no longer necessary or requested to do so. 

California Privacy Rights. California Civil Code section 1798.83 permits customers who are California residents to request certain information regarding disclosure within the immediately preceding calendar year of that resident’s Personal Information to third parties and in some cases affiliates for their direct marketing purposes. To make such a request, contact us through the information provided below. Please note that we are only required to respond to one request per customer each year, and we are not required to respond to requests made by means other than through the email address. For your protection, you will be required to provide proof of your identity to obtain a copy of your Personal Information. 

Rules When You Access the Service from Within the EEA

If you access our Service from within an EEA Member State, the following privacy rules apply to you.

The Purposes For Which We Collect Information From You. We only process your Personal Information if we have a lawful purpose pursuant to Article 6(1) GDPR. The following lawful purposes apply to such information that we collect from you: 

  • Necessary Collection To Perform Services (Article 6(1)(b) GDPR). We need the Personal Information that we collect in order to fulfill our obligations and perform the services that you and we agreed upon for the Game.
  • Consent Based Collection (Article 6(1)(a) GDPR). We collect your Personal Information for the Newsletter because you gave us your explicit consent to use this information when you signed up for the Newsletter. You may withdraw this consent, and we will cease to use your Personal Information for this purpose, by your request to support@usagishima.net. 
  • Other Purposes. We may process your information when we are legally obliged to under GDPR Article 6(1)(c) (for example for tax purposes), it is necessary in order to protect the vital interests of you or someone else under GDPR Article 6(1)(d), it is necessary in public interest under GDPR(6)(e), or for security reasons, to better understand your and others interest and preferences for our Services and improve our Services, for internal purposes (for example for auditing), and to secure and enforce our rights under GDPR Article 6(1)(f).

Your Data Rights. You have the right to correct, update and change (if the information we process is incorrect), or delete Personal Information or demand from us to release such information, as well as restrict how we use or entirely end the use of such information, by sending an email to support@usagishima.net. Your rights, however, may be limited, for example we will keep Personal Information if, at the time or foreseeable future, it is necessary for us to establish, exercise, or defend against a legal claim.

Withdrawing Consent. If we have received your information from you because of your explicit consent, you can withdraw this consent at any time by sending an email to support@usagishima.net. 

Transferring and Sharing Data. We will never transfer your Personal Information to a third party or a successor of ours that resides in a country that does not adhere or cannot guarantee the same privacy protection standards as provided by the GDPR. Currently we share your Personal Information with the following parties outside of the EEA, all of which protect your rights pursuant to the GDPR:

  • We share your Personal Information with GameAnalytics for purposes of game analytics. GameAnalytics is located in the United Kingdom and ensures compliance with the GDPR by implementing the Standard Contractual Clauses or an International Data Transfer Agreement in our agreement with them for their services. You can view GameAnalytics’s privacy protection standards at https://gameanalytics.com/trust/privacy/privacy-notice.
  • We share the Personal Information that we collect automatically through your use of the Game with Google LLC for purposes of managing purchases, to report and sync player’s achievement data, and advertising. Google LLC is located in the United States and applies the Standard Contractual Clauses or U.S. Data Privacy Frameworks. You can view Google LLC privacy protection standards at https://business.safety.google/adsdatatransfers/ and https://policies.google.com/privacy/frameworks?hl=en-US.
  • We share your Personal Information with Apple Inc. for purposes of enabling purchases, and reporting and syncing players’ achievement data. Apple Inc. is located in the United States and ensures compliance with the GDPR by implementing the Standard Contractual Clauses in our agreement with them for their services. You can view GameAnalytics’s privacy protection standards at https://www.apple.com/legal/privacy/en-ww/.
  • We share your Personal Information with Unity Software Inc. for purposes of monetization. Unity Software Inc. is located in the United States and ensures compliance with the GDPR by implementing the Standard Contractual Clauses in our agreement with them for their services. You can view GameAnalytics’s privacy protection standards at https://unity.com/legal/game-player-and-app-user-privacy-policy.
  • We share your personal information with Automattic, Inc. for purposes of providing news and announcements about the Game. Automattic, Inc. is located in the United States and ensures compliance with the GDPR by adopting contractual measures suitable to ensure adequate data protection. You can view Automattic, Inc.’s privacy protection standards at https://www.thenewsletterplugin.com/legal/privacy

Parental Control. Children Under Eighteen. We do not acquire Personal Information based on consent from children under the age of eighteen. If you believe that your child’s Personal Information was mistakenly collected through our Service, please contact us immediately at support@usagishima.net and we will work with you to determine if this is the case and grant you the rights under this Section.

Liability For Data Breach By Third Parties. If we share your Personal Information with a third party that processes the information on our behalf, we will be liable for that third party’s processing of your information in violation of the GDPR and this Privacy Policy, unless we can prove that we are not responsible for the event giving rise to the damage.

Complaint. If you believe that your rights described in this Privacy Policy are violated or you believe that we have not held ourselves to the standards described in this Privacy Policy or under the GDPR, you have the right to lodge a complaint with the respective supervisory authority in the country of your residence.   

Changes to our Privacy Policy

We may make changes to this Privacy Policy from time to time. If so, we will notify you of any material changes via an in-game notification and posting a notice within our Services. If you receive notification of a change in our Privacy Policy, you must review the new Privacy Policy carefully to make sure you understand our practices and procedures. We raise your attention that you may not be able to receive notices from us, including of such changes to the Privacy Policy, if your cookies are disabled.

Contact

For further information on our Privacy Policy, or for questions or requests on information that we may have collected from you, please contact us at support@usagishima.net. 

Pui Pui Yu
Josephsplatz 8
90403 Nuremberg
Germany

Last updated: December 1, 2023