ARC SYSTEM WORKS PRIVACY POLICY

Last Updated: March 19, 2026

Kidooka Minoru, CEO
Arc System Works Co., Ltd

1. General Provisions
2. Information We Collect
3. Purposes of Use and Sources of Personal Information
4. Retention Period for Personal Information
5. How We Share Personal Information
6. Privacy Practices for Customers Under 16
7. How We Protect Personal Information
8. How to Modify, Delete, or Export Your Personal Information
9. Links to Third-Party Websites and Services
10. Updates to This Privacy Policy
11. Personal Information of Customers Resident Outside of Japan
12. Rights of EEA Residents
13. Contacting Us

1. General Provisions
Arc System Works Co., Ltd. (hereinafter referred to as “”our company””) is a game development, sales, and distribution company committed to “”enriching the world.””
When entrusted with personal information, we consider protecting that information to be an important corporate responsibility and social mission. Our directors, employees, and all other personnel involved in our business comply with all laws, regulations, national guidelines, and other standards regarding personal information protection. We also pledge to make a company-wide effort to continuously improve personal information protection.
This Privacy Policy applies solely to the collection, use, and disclosure of information we may receive through your use of our website, applications, software, services, and other online activities, or participation in eSports events (hereinafter referred to as “Services”).

A. Establishment of “”Personal Information Protection Program””
We recognize the risks of unauthorized access to personal information, as well as loss, destruction, falsification, and leakage of personal information, and take necessary measures to prevent and correct such risks.
We have also established “”Personal Information Protection Program,”” which set out standards, rules, and procedures for the appropriate handling and management of personal information.

B. Organizational Activities for Personal Information Protection
To put this Privacy Policy into practice, we will take the following actions.
(1) We will appoint a Data Protection Officer (DPO) and assign him or her the responsibility and authority for implementing and administering personal information protection.
(2) We will appoint a Personal Information Protection Auditor and conduct internal audits of the operations and implementation status related to personal information protection.
(3) We will request cooperation from business partners and individuals regarding the protection of personal information.
(4) We will make this Privacy Policy available to anyone inside and outside the company at any time by updating and posting it on our website and intranet.

C. GDPR Compliance
In this Privacy Policy, “”GDPR”” refers to Regulation (EU) No. 2016-679 of 27 April 2016 on the protection of individuals with regard to the processing of personal data and on the free movement of such data. “”EEA”” refers to the European Economic Area (EEA).

2. Information We Collect
Through our Services, we may collect both personal information that can be used to identify and contact you, and non-personal information that cannot be directly associated with you. This may include the IP address you use to access our Services and technical information, including IP information for your device ID or virtual device identifier.

A. Data You Provide to Us
We collect and store personal information you provide when you purchase, register, use, or inquire about our Services, participate in an event, promotion, or mailing list, complete a survey, or apply for employment with us. This information includes:
● Contact information, such as email address, address, and phone number
● Account ID and password
● Profile information, such as profile photo
● Transaction information, including payment information
● Communication history with us, including related to customer support inquiries and chat logs
● Resume information, such as educational background, employment history, and qualifications, and business contact information
● Other data you provide when using the Services”

B. Data Collected Automatically
We automatically collect and store certain technical, game-related, and customer purchase information to generate aggregate statistics that help us improve our Services. Most of this information is non-personal and cannot be used by itself to identify you. However, this data may be used to identify you when combined with other information. This information includes:
● Account and purchase history data
● Internet location and device identifiers
● Additional information about your device, such as device name, operating system, browser type, and language
● Location data (IP address and information from your ISP)”
C. Data Collected from Third Parties (Service Providers, Business Partners and Our Group Companies) We may combine personal information collected on our website with data obtained from third parties for the purpose of improving our Services or market analysis.
● Data from third-party tools or linked social networks (such as Facebook or Google)
● Data used to investigate and prevent click fraud, fraudulent refunds, kickback fraud, etc.
● Analytics and advertising-related data to provide you with access to quality games and our Services.

3. Purpose of Use and Sources of Personal Information
A. Sources of Personal Information We Collect
We collect your information (1) directly or through your use of the Services, (2) through your interactions with SNSs, and (3) from third parties, such as service providers, business partners, and our group companies (collectively, “”Entities””).
By registering with an SNS login information, you allow us to access certain information from your profile on that SNS. You can register the information you allow us to access in the SNS’s privacy settings. You can view these settings on the SNS.
In addition, if you are a member of an SNS, the Services may allow you to log in through an interface provided by the SNS. The Services may also allow you to access an SNS through the Services themselves. If you log in to one of our Services using an SNS or access an SNS through one of our Services, we may receive personal and non-personal information that you have provided (or will provide in the future) to that SNS.”
By connecting the Service to an SNS, you consent to our access, use, and storage of the information the SNS provides to us in accordance with this Privacy Policy. Additionally, by logging in to the Service through an SNS, such as Facebook, you consent to the SNS viewing your cookies and receiving information about your website activities when you access our website through the SNS. You may be able to specify the information provided to us by the SNS using your SNS privacy settings. We also collect personal information when you participate in an eSports event as a player, prize winner, or contestant (each a “Promotion”) through a third-party platform. If you choose to participate in a Promotion, you will be asked to provide personal information such as your email address and mailing address. If you are the winner of the applicable Promotion, we may request your government-issued identification information to verify your identity.

B. Cookies and Other Technologies
Cookies are text strings that service providers, such as Google or Google Analytics, send to your computer’s browser. Cookies on our Services are used solely to retrieve browser- or device-specific information. Cookies are necessary for our games to function properly, to allow you to continue your gameplay experience from one session to the next, and to prevent you from having to re-enter your region and language each time you visit our Services. Cookies can also tell us, for example, which parts of our Services are most popular, how much time users spend there, and how users interact with the content. Cookies may be linked to your account ID. We do not collect information from your computer unrelated to our Services. We require your explicit and free consent to use cookies for each service, which is displayed via a “”banner.”” Cookies will not be used if you do not consent.
You may be given the option to disable cookies by changing your browser options to stop accepting cookies or by prompting you before accepting a cookie from the pages you visit.
Additionally, you can disable or delete data in browser add-ons, such as Flash cookies, by changing the add-on settings or visiting the add-on’s manufacturer’s website. However, if you do not accept cookies, you may not be able to use all portions of our Service.
We may also use “”pixel tags,”” “”web beacons,”” “”clear GIFs,”” or similar means (individually or collectively, “”Pixel Tags””) in connection with our Services to collect usage, demographic, and geolocation data. A pixel tag is an electronic image—a single pixel—that is typically not visible to users and may be associated with a cookie on a user’s device or hard drive. Pixel tags allow us to count users who have visited certain pages on our Services and help us determine the effectiveness of promotional or advertising campaigns.
Please note that third parties who serve advertisements through our Services may also use cookies or other technologies. Their use of cookies and other technologies is subject to their own privacy policies and terms of use.
By clicking the “”Sign Up”” button or otherwise accessing or using our Services, you consent to the use of cookies and other tracking technologies on your computer or device.

C. How We Use the Personal Information We Collect
We use your information to provide you with a streamlined and personalized experience. For example, we may use information in the following ways to provide our Services:”
● To send important notices, such as purchase communications and changes to our Terms of Use, End User License Agreement (EULA), and this Privacy Policy.
● To provide the Services.
● To allow you to reset your forgotten password.
● To provide technical support and respond to your inquiries.
● To prevent fraud and illegal activity and enforce our Terms of Use and EULA.
● To monitor the performance of our outside vendors and distributors.
● To notify you about and promote new products.
● To contact you about potential events, sweepstakes, and promotions, and to inform you of participation requirements and offer rewards or prizes.
● To collect demographic information about our users to more effectively administer the Services and deliver targeted advertising.
● To administer and administer tournaments, verify eligibility, award prizes, and verify shipping addresses.

To help develop, provide, and improve the Services. For customers located in the EEA, our legal basis for processing this personal information is to provide you with the Services you request and to prevent fraud or harm to the Services and other customers.
Our legal basis for processing customers’ personal information in the EEA is our “”legitimate interests,”” which are, among other things, to avoid irrelevant recommendations and optimize your experience with the Services. If you or your data controller resides in the EEA, you have the right to object to this processing at any time. To exercise this right, please email privacy@arcsy.co.jp or access the “”Personal Information Request Form”” on our website.
When we send you emails or SMS messages to promote our products or Services, or the products and services of our partners, we provide you with the option to receive additional promotional messages. In most cases, you can set up “”push”” notifications through the Services or your computer or device.

4. Retention Period of Personal Information: We will only store your information for as long as necessary to fulfill the purposes for which it is collected and processed, or for the legally required storage and retention period if applicable law provides for a longer storage and retention period, after which your personal information will be deleted.

5. How We Share Information
A. Third-Party Advertisers
We do not share your personal information with third-party advertisers, ad networks, and ad platforms (“”Advertisers””) for their direct marketing purposes unless you consent to it. We may share certain non-personal information with Advertisers to develop and deliver targeted advertisements on the Services and on third-party websites. We may also allow Advertisers to collect non-personal information related to the performance of their advertisements, such as the number of times an advertisement is displayed, the length of time an advertisement is displayed, and click-throughs on the advertisement. Advertisers may collect this information using tracking technologies such as browser cookies and web beacons.

B. With Other Service Providers
To help administer the Services, we may use and share your information with third-party service providers. These service providers will have access to your information only to perform the services they have been engaged to perform for us, and they have agreed not to disclose or use it for any other purpose. These service providers include:
● Payment processors, billing and refund vendors for the purposes of providing the Services;
● eSports organizers, hosts and venues in order to assure fair and appropriate administration of eSports events in connection with the Service;
● Postal services for the purposes of delivering rewards and prizes to you for events and Promotions you may participate;
● Joint sponsors for events and Promotions you may participate;
● Data management or data analysis provider.

C. Within our Group
Our company, its subsidiaries, and affiliated companies may jointly use personal information as follows:
⚫ Items Shared
・Contact information, such as email address, address, and phone number
・Account ID and password
・Profile information, such as profile photo
・Transaction information, including payment information
・Interaction history with us, including related to customer support inquiries and chat logs
・Resume information, such as educational background, employment history, and qualifications, and business contact information
・Other data you provide when using the Services
・Data related to your account and purchase history
・Internet location and device identifiers
・Additional information about your device, such as device name, operating system, browser type, and language
・Location data (IP address and information from your provider)
・Data from third-party tools or linked social media platforms (such as Facebook and Google)
・Data used to investigate and prevent click fraud, fraudulent refunds, kickback fraud, etc.
・Data related to analytics and advertising to provide you with quality games and access to the Services
⚫ Scope of joint use
・Arc System Works America, Inc.
https://arcsystemworks.com/company/
・Arc System Works Asia Co., Ltd.
https://www.arcsystemworks.asia/
・Arc System Works Europe S.A.S.
https://www.arcsystemworks.fr
・UnitePlus Co., Ltd.
https://www.uniteplus.jp/

⚫ Purpose of Use
・To send important notices, such as purchase-related communications and changes to our Terms of Use, End User License Agreement (EULA), and this Privacy Policy.
・To provide the Service.
・To allow you to reset your forgotten password.
・To provide technical support and respond to your inquiries.
・To prevent fraud and illegal activity and enforce our Terms of Use and EULA.
・To monitor the performance of our third-party vendors and distributors.
・To notify you about and promote new products.
・To contact you regarding sweepstakes and promotions, including administering potential tournaments, verifying eligibility, awarding prizes and verifying mailing addresses, and conducting marketing (with your consent).
・To deliver and target advertisements from third parties for market research purposes to provide valuable services to our user community.
・To collect demographic information about our users to more effectively administer the Service and provide targeted advertising.

⚫ Management Representative
Shin-Yokohama Kaneko Building, 2-3-9 Shin-Yokohama, Kohoku-ku, Yokohama
Arc System Works Co., Ltd.
Representative Director: Minoru Kidooka

D. Special Circumstances
We may disclose your personal information to law enforcement or private authorities when we, in our sole belief, believe such action is necessary to protect our property and rights, protect the safety of third parties, prevent illegal or unethical activity, serve legal process (including, but not limited to, a subpoena), or as otherwise permitted by applicable law.
If you or the relevant data controller is a resident of an EEA country, our legitimate interest in sharing this information is to comply with our legal obligations and to protect the vital legitimate interests of a closely related third party. We may sell, transfer, or otherwise share some or all of our assets, including your personal information, in connection with a merger, acquisition, reorganization, or sale of assets, or in the event of bankruptcy.

6. Privacy Policy for Customers Under 16
We do not knowingly collect personal information about customers under 16 without the permission of their parents or legal guardians. We are the only legal entity authorized to use personal information collected about customers under 16. Under no circumstances will this information be sold or transferred to third parties without the prior consent of the parent or legal guardian.
The privacy of children under 16 is our priority, and we encourage parents to take an active and ongoing interest in the online activities of their children under 16. If we discover that we have inadvertently collected personal information about a customer under 16 without the permission of a parent or legal guardian, we will immediately take all necessary and reasonable measures to delete the information from our systems. Online users may request the deletion of their personal information. We will promptly delete the data unless a different retention period is required by law.

7. How We Protect Personal Information
We are committed to protecting the security of your information. To protect against leaks and unauthorized access of personal information, we have implemented company-wide security measures based on our established “”Personal Information Protection Program.”” For details about these security measures, please contact us by email at privacy@arcsy.co.jp.

We will never request credit card information, login information, or other identification via unsecured or unsolicited communications (e.g., email). In the event of a security breach, we will promptly disclose any legally required information by email or posting it on the Service, taking into consideration (i) requests from law enforcement authorities and (ii) efforts to identify the scope of the breach and restore data systems.”
“8. How to Modify, Delete, or Export Your Personal Information
You can request disclosure, modification, or deletion of your personal information by using the “”Personal Information Request Form”” on our site. We will make reasonable efforts to fulfill your request. We may retain a copy of your records for legal or administrative purposes.
Please note that communications sent through the Services and comments posted may be stored by us and may not be subject to modification or deletion.
You can also manage the information we collect through your browser settings. You can prevent the Services from obtaining location information by configuring your browser to reject cookies from us and adjusting the settings on your game console. However, please note that the Services may rely on cookies and location information to function properly, and disabling cookies may prevent you from using some of the Services.

9. Links to Third-Party Websites and Services
The Service may contain links to other websites and other online services, including advertisements for third parties. Please note that if you click on these other websites or online services, the privacy policies and other terms of use of those websites or services, rather than our Privacy Policy, will apply. We do not control third-party websites or services, and the fact that links to such websites or services appear on the Service does not imply approval or endorsement of their policies or practices related to user information. We encourage you to review the privacy policies and other terms of use of third-party websites or services before providing information to them. You agree that we are not responsible for any issues related to third-party websites or services to which you provide information, including the collection and processing of that information.

10. Updates to this Privacy Policy
We reserve the right to update this Privacy Policy at any time. If we make any material changes to this Privacy Policy, we will notify you on our website and post the updated Privacy Policy. We will also update the “”Last Updated”” date of the Privacy Policy. As used herein, “”Privacy Policy”” includes any updates and changes we may make from time to time.
By continuing to access or use the Services after we post an updated Privacy Policy or provide you with notice of any changes, you agree to be bound by the revised Privacy Policy. If the revised Privacy Policy is unacceptable to you, you must immediately stop using the Services.

11. Personal Information of Customers Resident Outside Japan: Personal information you provide may be transferred to or accessed by entities around the world, as described in this Privacy Policy. If you reside outside of Japan, please understand that we may transfer and process your personal information in Japan. If you reside in the European Union, you consent to the transfer of your personal information outside the European Union and agree to implement appropriate technical, organizational, and security measures to protect your personal information during storage and transmission. However, personal information of customers under the age of 16 will not be sold or transferred to third parties without the prior consent of their parent or legal guardian. We will also take other measures reasonably necessary to protect your data or comply with the requirements of European Union data protection law and EU Data Protection Directive 95/46/EC. Your consent to this Privacy Policy and subsequent submission of your personal information represents your consent to these transfers.

12. Rights of EEA Residents
A. Data Controller
For purposes of this Privacy Policy, Arc System Works Co., Ltd. is the data controller of your personal information.

B. Rights of EEA Residents
If you are accessing or using the Website from within the EEA, you may have the following rights (and other rights) under the GDPR.
If you would like to exercise any of these rights, you may do so by emailing privacy@arcsy.co.jp, contacting us via the “”Personal Information Request Form”” on our website, or as described in the applicable section below.
Right of Access: You have the right to obtain from us confirmation as to whether we process your personal information and to obtain access to your personal information that we store at any time.
Right to Correct Your Personal Information: Where we process your personal information, we will take reasonable steps to ensure that your personal information is accurate and up-to-date for the purposes for which it was collected. If your personal information is inaccurate or incomplete, you have the right to request that we correct it.
Right to erasure of your personal information or right to restriction of processing: You may have the right to request that we erase your personal information or restrict the processing of your personal information.
Right to withdraw consent: If you have consented to the processing of your personal information, you have the right to withdraw that consent at any time, without affecting the lawfulness of processing based on consent before its withdrawal.
Right to data portability: You may have the right to receive personal information about you and provide it to us in a structured, commonly used and machine-readable format or to transmit this data to another controller.
Right to object: You may have the right to object to the processing of your personal information as further specified in this Privacy Policy.
Right to define post-death instructions: You may give instructions regarding the storage, erasure and communication of personal data after death to an accredited, trusted third party responsible for enforcing the deceased’s wishes in accordance with the applicable legal framework.”
Right to lodge a complaint with a supervisory authority: You have the right to lodge a complaint with a data protection supervisory authority in the European Union. For more information on how to contact your local data protection authority, see https://ec.europa.eu/info/law/law-topic/data-protection_en.

13. Regarding Personal Information of Residents of California, USA
We hereby disclose the following information regarding our handling of personal information of residents of California, USA.

13-1. California Civil Code Section 1798.83
California Civil Code Section 1798.83 permits California residents to request certain information regarding our disclosure of personal information to third parties for their direct marketing purposes. However, we do not share information with third parties for their direct marketing purposes. For questions regarding our disclosure policy, please contact us at the address or email address below.
2-3-9 Shin-Yokohama, Kohoku-ku, Yokohama, 222-0033
Arc System Works Co., Ltd., Personal Information Protection Officer (DPO)
Email: privacy@arcsy.co.jp

13-2. Sale of Personal Information
We have not sold any personal information of California residents, as defined in the California Consumer Privacy Act (CCPA), as amended, the California Privacy Rights Act (CPRA), during the past 12 months.

13. Rights of California Residents
You have certain rights in connection with the collection of your personal information as a resident of California. You may exercise the following rights regarding your personal information, subject to certain exceptions and limitations, by contacting us via our online form. Before fulfilling your request, we may ask you to provide reasonable evidence to verify your identity for your safety or to comply with the law.

(a) Right to Know
You may make a verifiable request, free of charge, up to two times every 12 months for the following information:
– The specific information we hold about you
– The categories of personal information we have collected, sold, or disclosed for a business purpose in the past 12 months
– The categories of sources from which the personal information was collected
– The purposes for which the personal information was collected or sold
– The categories of third parties to whom the personal information was sold, disclosed for a business purpose, or otherwise shared
To the extent possible, we will provide this information in a readily available format that allows you to transmit it to another entity.

(b) Right to Correct
You may make a verifiable request to correct any inaccurate personal information that we have collected about you. Upon verifying the validity of your correction request, we will use commercially reasonable efforts to correct your personal information as directed, taking into account the nature of the personal information and the purposes of maintaining your personal information.

(c) Right to Deletion
You may make a verifiable request to delete the personal information we have collected about you. We will contact you within 11 business days of receiving your request to confirm receipt. We will provide you with a substantive response as soon as possible after that, unless we need more time, in which case we will notify you. If we need additional information to verify your identity, we will contact you and request the necessary information. If we are unable to verify your identity, we will deny your deletion request. If we deny any part of your request, we will provide a reason for such decision.
We may deny your request for deletion if retaining the information is necessary for us or our affiliates to:
a. Complete the transaction for which we collected the personal information and provide access the service that you requested;
b. Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity or prosecute those responsible for such activities;
c. Comply with legal obligations; or
Make other internal and lawful uses of that information that are compatible with the context in which you provided it.

(d) Right to Opt-Out of Sale
We will not sell any of your information to any third party.

(e) Right to Opt-Out of Sharing.
As the terms are defined under the CPRA, we “shared” certain data elements within the following categories of personal information: [Identity Data, Usage Data, and Technical Data/Networking Activity].
If you would like to opt out of the sharing of your personal information, you may click the “DECLINE ALL” button in our Cookie banner.”

(f) Right to Non-Discrimination: We will not discriminate against you because you choose to exercise your rights, such as by denying you access to our game services or online services or charging you different fees or prices for the same online services, unless such difference in treatment is reasonably related to the value of your personal information.

You may designate an authorized agent to submit requests on your behalf by designating such an agent in writing. We may require the agent to provide us with proof that you have authorized the agent to make requests on your behalf prior to accepting requests from the agent.
We do not sell or share the personal information of minors under 18 years of age without their parent’s or legal guardian’s prior, verifiable consent.

14. Contacting Us
If you have any questions, inquiries, requests, or complaints regarding this Privacy Policy or our information handling practices, please email privacy@arcsy.co.jp, submit a request via the “”Personal Information Request Form”” on our website, or mail it to the address below.
When contacting us, we may request you to submit identification documents as necessary.

Arc System Works Co., Ltd. Customer Service Center, Personal Information Protection Officer (DPO)
Shin-Yokohama Kaneko Bldg,
2-3-9 Shin-Yokohama Kohoku-ku,
Yokohama-shi, Kanagawa-ken 222-0033
Personal Information Request Form