KODANSHAtech LLC.  (the “Company”, “we”, “us”, “our”) recognizes the importance of your personal information, and hereby prescribes and applies this Privacy Policy for the proper collection, use and protection, as well as the safety control, of your personal information.

1. Definition of personal information

In this Privacy Policy, the term “personal information” means information about a living individual which corresponds to one of the following.

• Information which can identify a specific individual by name, date of birth or other description contained in such information {meaning any matter (excluding an individual identification code) stated, recorded or otherwise expressed using voice, motion or other methods in a document, drawing or electromagnetic record (meaning a record which is created in electronic form, magnetic form, or any other form that cannot be perceived by the human senses)} (including such information as will allow easy reference to other information and will thereby enable the identification of the specific individual).
• Information which contains an individual identification code.

2. Management of personal information

The Company will properly manage your personal information by prescribing application guidelines related to the protection of personal information, and appointing a personal information administrator.

3. Collection of personal information

When collecting your personal information,  will designate the purpose of utilization of your personal information and notify you of such purpose of utilization in advance, and collect and use your personal information by adequate means within the scope required for attaining such purpose of utilization. Furthermore, unless otherwise prescribed in the “Act on the Protection of Personal Information” (Act No. 57 of 2003; hereinafter referred to as the “Personal Information Protection Act”), The Company will not use the collected personal information for any purpose other than for the purpose of utilization without obtaining your prior consent, and will endeavor to promptly erase your personal information after attaining the purpose of utilization.

4. Purpose of utilization of personal information

The Company may ask you to provide your personal information for the following purpose of utilization. When collecting and using your personal information for any purpose other than the following purpose of utilization, The Company will notify you of such purpose of utilization pursuant to the preceding paragraph.

1. To provide services for registered members

2. To send products and prizes that you ordered or applied for

3. To conduct research and analysis through questionnaires in order to improve our existing services, develop our new services, and maximize customer satisfaction, etc.

4. To notify results to persons who cooperated with our questionnaires or events

5. To provide information through direct mails or emails, etc.

6. To improve or upgrade services or develop new services of The Company’s website or various online services (hereinafter collectively referred to as the “Official Site, etc.”)

7. To analyze your interests and preferences using information collected by The Company and its affiliated companies, etc. in order to improve The Company’s services, such as contacting, informing and guiding you about products and events that better meet your needs

8. To execute business operations related to the purposes of 1 to 7 above
   In the Official Site, etc., you can choose whether or not to provide your personal information to The Company based on your own judgment; provided, however, that, if you decide not to provide your personal information to The Company, you may not be able to use the services offered in the Official Site, etc.

5. Provision of personal information to a third party

The Company will not provide your personal information to any third party unless we obtain your approval, such provision is based on the Personal Information Protection Act or other laws and regulations, or any of the following cases apply.

• Cases in which the provision of personal data is necessary for the protection of the life, body, or property of an individual and in which it is difficult to obtain your consent
• Cases in which the provision of personal data is especially necessary for improving public health or promoting the sound growth of children and in which it is difficult to obtain your consent
• Cases in which the provision of personal data is necessary for cooperating with a state organ, a local government, or an individual or a business operator entrusted by one in executing the affairs prescribed by laws and regulations and in which obtaining your consent are likely to impede the execution of the affairs
• Cases of confirming the validity of bank accounts or credit cards of users with financial institutions or credit card companies in connection with the credit card payment of fee-based services or ordered products
• The Company will not provide your personal information to a third party located overseas unless we obtain your approval or such provision is allowed under the Personal Information Protection Act.
• When you purchase or use The Company products, respond to surveys, enter campaigns or otherwise use The Company’s services, The Company may provide personal information in its possession to Content Data Marketing Inc., an affiliate of The Company, to the extent necessary for The Company and Content Data Marketing Inc. to provide improved services. For information on the purposes of use of your personal data by Content Data Marketing Inc., please refer to the privacy policy of Content Data Marketing Inc.

6. Records, etc. upon provision and reception of personal information

When The Company is to provide personal information to a third party (excluding a state organ, local government, incorporated administrative agency, etc. and local independent administrative institution; hereinafter the same in this paragraph) or receive personal information from a third party, we will create records concerning necessary matters pursuant to the Personal Information Protection Act, and store such records during the period prescribed in the Rules of the Personal Information Protection Commission.

7. Security Control Measures for protection of personal information

The Company will take necessary and proper systematic, human, physical and technical security control measures for the prevention of leakage, loss or damage of personal information. For more information on security control measures, please contact us via the method set forth below in “11) Contact us”.

8. Entrustment to a third party

When The Company is to entrust the handling of personal information to a third party, we will appoint a proper trustee, exchange a contract related to the protection of personal information with the trustee, and exercise necessary and appropriate supervision over the trustee.

9. Disclosure, correction suspension or deletion of use of personal information

When The Company receives your request for notification of the purpose of use, disclosure, correction, addition, deletion, suspension of use, deletion, suspension of provision to a third party, or disclosure of the record of provision to a third party (hereinafter referred to as “disclosure, etc.”) of retained personal data, or in the event that an inquiry is made regarding safety control measures for the protection of personal information, we will respond appropriately in accordance with the Personal Information Protection Law and other laws and regulations.
For information on the procedures for disclosure, etc., please use this Contact form. Please note that in some cases, identification documents may be required for the person in question.

10. Amendment of this Privacy Policy

The Company may amend this Privacy Policy without prior notice due to changes in social situations, advancement of technologies or revision of the Personal Information Protection Act.

Please note that this Privacy Policy shall not apply to cases of news coverage, etc.

11. Contact us

If you have any inquiries regarding the subject matter of this page, please use this Contact Form.

Use of access data in The Company’s official website and various online services

The website and various online services operated by The Company (hereinafter collectively referred to as the “Official Site, etc.”) will handle the access data of users in the Official Site, etc. with utmost attention as described below. Furthermore, The Company will handle the collected personal information according to the foregoing Privacy Policy.

1. Definition of access data

The term “access data” means, among all information handled by The Company which can directly or indirectly identify a user as an individual (hereinafter referred to as the “Personal Data”), date/time and frequency of access, IP address, terminal, browser (internet browser) and type/version of OS used, screen size, Cookie information, referrer information, GPS position information, browsing history of pages and articles, time spent on each page, and trail of the cursor (mouse).

2. Purpose of utilization of access data

The Company may automatically acquire the access data of users of the Official Site, etc. for the following purpose of utilization.

1. To provide services for registered members

2. To notify results to persons who cooperated with our questionnaires or events

3. To provide information through direct mails or emails, etc.

4. To distribute ads (targeted ads) that meet the needs of users, confirm the status of distribution, and measure the effect of such ads

5. To improve or upgrade services or develop new services of the Official Site, etc.

6. To execute business operations related to the purposes of 1 to 5 above

3. Use of Cookies

A Cookie is information that is exchanged between the web server and your browser when you browse a webpage, and is recorded at a prescribed location of the browser when the setting on your PC or mobile terminal accepts the use of Cookies; provided, however, that the recorded information does not include any information which can identify a specific individual, such as the username or email address. In the Official Site, etc., you can use the information remaining in the Cookies and change the display to your liking. You can also change the setting of the browser to refuse the use of Cookies or to display a warning when Cookies are being used; provided, however, that, in such a case, please note that you may not be able to use certain services or functions depending on the site.

4. Opt-out (disabling) of Cookies

You can change the setting of your browser to receive a notice when Cookies are being used or refuse the use of Cookies. If you refuse the use of Cookies, articles and ads that meet your needs may no longer be displayed or distributed, or the same ad may be repeatedly distributed.

5. Web beacon

The Official Site, etc. and certain HTML email magazines may acquire the access status of the Official Site, etc. by combining a technology known as “web beacon” with Cookies.

6. Ad distribution by a third-party service provider

In certain sites and services among the Official Site, etc., The Company is entrusting the ad distribution to a third-party service provider for the ads to be displayed on such sites and online services, and The Company’s ads to be displayed on various external websites and online services. For the ad distribution described above, the ad provider as our trustee may also acquire and use your Cookies. In such a case, the acquired Cookies will be stored and managed on the server of the ad provider, and not on our web server.

7. External links

The Official Site, etc. may include links to external websites. Please note that The Company will not be responsible for the handling of your Personal Data in such external websites.

8. Community function

Certain sites and services among the Official Site, etc. provide bulletin boards and comment functions. Please do not post any content related to your personal information or the personal information of a third party in any service that can be viewed by other users. If you post contents related to your personal information or the personal information of a third party in these services, such personal information may be used or misused in a manner that is unintended by the owner of such personal information. In the foregoing case, The Company will not be liable in any way, and we ask that you exercise due care in using such bulletin boards and comment functions.

9. Social media link buttons

Certain sites and services among the Official Site, etc. provide social media link buttons. When you browse a site provided with social media link buttons, your access data may be automatically sent from the corresponding site to the social media even if you do not press the “Like!” button or “Share” button. Please properly use these sites based on your own judgment upon understanding the Terms of Use and the Privacy Policy of the social media that you are using.

10. Google Analytics

We use Google Analytics, a service provided by Google, to collect information about how people use the Websites. Google Analytics stores information about what pages you visit, how long you are on the sites, how you got there, and what you click on, etc. This information cannot be used to identify who you are. We receive the analysis results from Google and determine how you use the Websites therefrom. Such information is managed by Google in accordance with its privacy policy. Please visit the following Google website to obtain further information regarding how Google uses cookies.

HOW GOOGLE USES INFORMATION FROM SITES OR APPS THAT USE OUR SERVICES:

https://policies.google.com/technologies/partner-sites?hl=en-GB

If you have any inquiries regarding the subject matter of this page, please contact The Company.

Privacy Policy (For Residents outside of Japan)

This Privacy Policy (this “Global Policy”) applies only to residents outside of Japan. If you reside in California, please see The Company’s Privacy Policy (For California Residents).

KODANSHAtech LLC. (“The Company”) as data controller is responsible for protecting your personal data. We will collect and process your personal data pursuant to the EU General Data Protection Regulation (the “GDPR”) and other laws and regulations applicable to our processing of your personal data.

1. Contact Information

The contact information of KODANSHAtech LLC. is as follows:
Address: 2-21-21 Otowa, Bunkyo-ku, Tokyo
Email address: contact@kodansha.tech

2. Personal Data Processed

The Company will process the following personal data, that you provide to us, through the provision of its services:

• Information that can identify the person and contact information
  Including, for example, name, address, country of residence, telephone number and email address
• Information regarding the person’s attributes
  Including, for example, gender and date of birth
• Information regarding payment
  Including, for example, credit card information
• Information regarding the use of services
  Including, for example, website access data, records of services purchased and other purchasing or payment history
• Other personal data you provide to The Company

The term “access data” includes date/time and frequency of access, IP address, terminal, internet browser, type/version of OS, screen size, cookie information, referrer information, GPS position, browsing history, time spent on each page, and cursor trail from among the information processed by The Company that can directly or indirectly identify you.

In addition, The Company receives and processes the following personal data of the users of the games we publish from the operators who distribute those games:

• User’s nickname (ID).
• Information on use of the service

3. Purpose of Use and Legal Basis

The Company will process the personal data for the following purposes of use. Please note that the legal basis for processing personal data may vary depending on the jurisdiction. When a basis specified below does not apply in your jurisdiction, we will process your personal data based on an alternative basis permitted under the applicable laws and regulations, such as obtaining your consent.

1. For The Company’s legitimate interests in which personal data is strictly required to carry out its business activities (including the following purposes of use):

   1. To statistically process personal data, and use or provide the processed data;

   2. To conduct research and analysis through questionnaires in order to improve our existing services, develop our new services, and maximize customer satisfaction, etc.;

   3. To notify persons who filled out questionnaires or participated in events of the thereof;

   4. To improve or upgrade services or develop new services for The Company’s website or for various other online services;

   5. To respond to your enquiries regarding secondary use of our publications, etc.;

   6. To contact you as necessary for our business; and

   7. To manage The Company’s projects and other activities to which you have applied.

2. To comply with obligations under an agreement or to perform the procedures relating to an agreement (including the following purposes of use):

   1. To provide services to registered members and enable them efficient use thereof;

   2. To process and administer their personal account and register for those services;

   3. To send products and prizes that you ordered or applied for; and

   4. To process your payments.

3. To process personal data in the event you give consent (including the following purposes of use):

   1. To distribute targeted ads based on your use of The Company’s services and/or on third-party sites and applications, confirm the status of distribution, and measure the effect of such ads; and

   2. To provide information regarding The Company’s services and other products, etc. through direct mail or email, etc.

4. For purposes set forth in the laws and regulations (including the following purposes of use):

   1. For use in the event there is a need to maintain or acquire personal data to fulfill a legal obligation borne by The Company; and

   2. When responding to requests of the government or investigative agencies.

We do not make decisions that may affect you legally or in a similarly significant manner based solely on automated processes.

4. Recipients of Personal Data

The Company will process and provide your personal data to the following businesses:

• advertising networks and data analytics providers;
• shipping and payment companies;
• customer management service providers;
• IT infrastructure service providers
• web hosting vendors;
• security service providers; and
• cloud service providers

The Company will subcontract the processing of personal data after executing memorandums of understanding concerning the entrustment of the processing of personal data with service providers.

5. Transfer to Third Country

The Company may transfer your personal data to countries outside your country, including Japan, to provide its services. Such countries may have a lower level of data protection than your country. When providing personal data to third parties outside your country, The Company takes the necessary measures therefor, such as obtaining consent and concluding data transfer agreements, etc., in accordance with applicable laws and regulations.

In the event that the GDPR applies to the processing of your personal data, The Company will only transfer personal data to third countries where an adequacy decision has not been given if proper protective measures such, as of the standard data protection provisions set forth in Article 46(2) of the GDPR, are in place.

To obtain a copy of a document used for the protection of your personal data or to obtain detailed information, please send a letter to KODANSHAtech LLC. (2-21-21 Otowa, Bunkyo-ku, Tokyo ) or an email to contact@kodansha.tech.

6. Retention Period

The Company will retain your personal data for the period of time required to achieve the purpose of use set forth in this Global Policy. The decision on the retention period of personal data is based on (i) whether or not you continue to use The Company’s services, (ii) whether or not there are legal obligations that The Company must comply with, and (iii) whether or not there is a need to perform an agreement to which you are a party.

7. Your Rights

You may have specific rights as a data subject under applicable laws and regulations, such as (i) the right to request a copy of the personal data, (ii) the right to request revisions, (iii) the right to request deletions, (iv) the right to limit or stop the processing of personal data, and (v) the right to have the personal data provided to The Company for an agreement or under consent be structured and receive it in a form that is machine-readable (right of data portability). Regardless of your request for deletion, The Company will continue to retain the necessary information for measures against re-rolling, as permitted by law.

In addition thereto, where the GDPR applies, you also have (vi) the right to object to the processing of personal data, under certain conditions. Please refer to “9. Right to File Objection” below for details.

These rights may be restricted, for example, if a third party’s personal data is disclosed by complying with your request, if the rights of someone other than you (including The Company’s rights) will be infringed, or if retention is required or deletion of information of which its retention has exigent legitimate interests is required by the laws and regulations.

To exercise any of these rights, please send a letter to KODANSHAtech LLC. (2-21-21 Otowa, Bunkyo-ku, Tokyo) or an email to contact@kodansha.tech. Note we may require proof of your identity and full details of your request or complaint before we can process them. We will respond to your request or complaint within the timeframe determined by the applicable laws and regulations. It will not always be possible to resolve a complaint to everyone’s satisfaction. If you are not satisfied with The Company’s response to your request or complaint, you have the right to contact the supervising authorities to lodge a complaint. For details, see “11. Right to File Complaint with Supervising Authorities” below.

8. Right to File Objection

You may have the right to file an objection to the processing of personal data.

Where the GDPR applies, you can object to the processing based on legitimate interests. The processing of personal data subject to such objection includes profiling (which means analyzing and predicting your actions from your information; the same applies hereafter). If your personal data is processed for the purpose of direct marketing, you have the absolute right to refuse direct marketing and to refuse the profiling conducted for such purpose.

To exercise any of these rights, please send a letter to KODANSHAtech LLC. (2-21-21 Otowa, Bunkyo-ku, Tokyo) or an email to contact@kodansha.tech.

9. Right to Withdraw Consent

If The Company is processing personal data under your consent, you always have the right to withdraw such consent. This withdrawal will not have effect on the legality of any processing that was conducted under the consent granted before then.

To exercise this right, please send a letter to KODANSHAtech LLC. (2-21-21 Otowa, Bunkyo-ku, Tokyo) or an email to contact@kodansha.tech.

10. Personal Data Required to be Provided

The personal data that is required to be provided will be indicated on the form that you fill out. If the provision of personal data is required, The Company will not be able to provide its services to you unless proper information is provided.

11. Right to File Complaint with Supervising Authorities

You have the right to file a complaint with supervising authorities. Supervising authorities with which the complaint can be filed include the supervising authorities of countries where your place of residence or workplace is located or where the place the petition of the violation is initiated is located.

12. Changes to this Global Policy

The Company will update this Global Policy from time to time in its sole discretion. We encourage you to look for updates and changes to this Global Policy periodically. If we make a material change to this Global Policy, we will endeavor to notify you on our services pages, by email, and/or by other legally permissible communication as required by applicable laws.

13. Questions

To learn more about our privacy policies, standards, or codes, etc., please send a letter to KODANSHAtech LLC. (2-21-21 Otowa, Bunkyo-ku, Tokyo) or an email to contact@kodansha.tech.

Privacy Policy (For California Residents)

This Privacy Policy (this “California Policy”) applies only to residents of California.

KODANSHAtech LLC. (“The Company”) will collect and process your personal information pursuant to the California Consumer Privacy Act (“CCPA”).

1. Information We Collect

The Company collects information that identifies, relates to, describes, references, and is capable of being associated with or could reasonably be linked, directly or indirectly, to a particular consumer (“personal information”). In particular, The Company will collect, and has collected in the last twelve (12) months, the following categories of personal information (including sensitive personal information) from you:

Category	Examples
A. Identifiers	Name, postal address, country of residence, online identifier, internet protocol address, email address, account name, and other similar identifiers
B. Personal information categories indicated in the California Customer Records statute (Cal. Civ. Code § 1798.80(e))	Date of birth, preferred language, type of device, organization name, job title, telephone number, answers to questionnaires, and posts on social media
C. Characteristics of protected classifications under California or federal law	Race, sex, gender, and age
D. Commercial information	Records of services purchased and other purchasing or payment history
E. Internet or other electronic network activity information	Browsing history, search history, and information regarding your interactions with websites, applications, and advertisements
F. Sensitive personal information	Racial or ethnic origin

The Company obtains the personal information listed above from you for the duration of our relationship with you, including, without limitation, when you: (i) make a personal account for our services; (ii) access or use our services; and (iii) communicate with us regarding inquiries about our services.

2. Use of Personal Information

The Company may use your personal information for one or more of the following business purposes:

• To provide our services to you and enable your efficient use thereof;
• To process and administer your personal account and registration to our services;
• To process your payments;
• To deliver our products to you;
• To run promotions or campaigns or our services;
• To conduct research and analysis through questionnaires in order to improve our existing services, develop our new services, and maximize customer satisfaction, etc.;
• To provide notices regarding information about our services and other products;
• To serve advertisements to you on our applications based on your use of the services and/or on third-party sites and applications;
• To respond to your enquiries regarding secondary use of our publications, etc.;
• To respond to your enquiries regarding secondary use of our publications, etc.;
• For use in the event there is a need to maintain or acquire personal data to fulfill a legal obligation borne by The Company;
• To contact you as necessary for our business; and
• To comply with obligations under an agreement or to perform the procedures relating to an agreement.

3. Disclosure of Personal Information

The Company may disclose your personal information to a third party for business or commercial purposes. When we disclose personal information to service providers or contractors for business or commercial purposes, The Company enters into a contract that states such purposes and requires the service providers and contractors to keep such personal information confidential and to not use such personal information for any purpose except performing the contract.

In the preceding twelve (12) months, The Company has disclosed the following categories of personal information to the following categories of third parties for business or commercial purposes:

• Identifiers, personal information categories indicated in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)), and internet or other electronic network activity information to service providers, including advertising networks and data analytics providers; and
• Identifiers and personal information categories indicated in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)) to service providers, including shipping and payment companies; and
• All categories of personal information to service providers, including cloud service providers.

4. Sale or Sharing of Personal Information

The Company has shared your personal information collected from you with third parties for purposes of cross-context behavioral advertising in the preceding twelve (12) months. Therefore, you have the “right to opt-out” of such sharing of your personal information under the CCPA. For more information about the right to opt-out, please see 5(4) below.

The Company has not sold any personal information collected from you in the preceding twelve (12) months.

5. Your Rights under the CCPA

The CCPA provides specific rights regarding personal information to consumers who are residents of California. This Section describes your rights and explains how to exercise those rights under the CCPA.

(1) Right to Access Specific Information

You have the right to request that we disclose certain information to you about our collection, sharing, disclosure, and use of your personal information. Once The Company receives and confirms your verifiable consumer request, The Company will disclose any or all of the following information to you:

• The categories of the personal information that The Company has collected about you;
• The categories of the sources from which the personal information is collected;
• The Company’s business or commercial purpose for collecting, selling, or sharing such personal information;
• The categories of third parties to which The Company disclosed such personal information; and
• The specific pieces of personal information The Company has collected about you.

(2) Right to Request Deletion

You have the right to request that The Company delete any of your personal information that The Company has collected from you and retained, subject to certain exceptions. Upon receiving and confirming your verifiable consumer request, The Company will delete, and notify our service providers or contractors and third parties to whom The Company has sold or shared such personal information to delete, your personal information from The Company’s records, unless an exception applies.

The Company may deny your request for deletion if retaining the information is necessary for The Company or its service providers or contractors to:

• Complete the transaction for which The Company collected the personal information, provide a good or service that you requested, take actions reasonably anticipated within the context of The Company’s ongoing business relationship with you, or otherwise perform The Company’s contract with you;
• Help to ensure security and integrity to the extent the use of your personal information is reasonably necessary and proportionate for those purposes;
• Debug products to identify and repair errors that impair existing intended functionality;
• Exercise free speech, ensure the rights of other consumers to exercise their free speech rights, or exercise other rights provided by law;
• Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 et. seq.);
• Engage in public or peer reviewed scientific, historical, or statistical research that conforms or adheres to all other applicable ethics and privacy laws, when our deletion of the information is likely to render impossible or seriously impair the ability to complete such research, if you have provided informed consent;
• Enable solely internal uses that are reasonably aligned with your expectations based on your relationship with The Company and compatible with the context in which you provided the information; or
• Comply with legal obligations.

(3) Right to Request Correction of Inaccurate Personal Information

You have the right to request that The Company correct any inaccuracies regarding your personal information that The Company has collected from you and retained, subject to certain exceptions. Upon receiving and confirming your verifiable request, The Company will correct, and notify our service providers or contractors and third parties to whom The Company has sold or shared such personal information to correct your inaccurate personal information.

The Company may deny your request for correction if The Company determines that the contested personal information is more likely than not accurate based on the totality of the circumstances.

(4) Right to Opt-Out of Sale or Sharing

You have the right to opt-out of having your personal information shared for purposes of cross-context behavioral advertising. To exercise your right to opt-out of your personal information, you (or your authorized representative) may submit a request through one of the following methods: The manner set forth in Section 8 (Contact Us)

(5) Right to Limit the Use and Disclosure of Sensitive Personal Information

The Company has not used or disclosed and will not use or disclose sensitive personal information collected from you for any purpose other than the following:

• Perform the services or provide the goods reasonably expected by an average consumer who requests such goods or services;
• Help to ensure security and integrity to the extent the use of your personal information is reasonably necessary and proportionate for those purposes;
• Short-term, transient use (except those involving profiling or changes to the future consumer experience);
• Perform services on behalf of us; and
• Undertake activities to verify or maintain the quality or safety of a service or device that is owned, manufactured, manufactured for, or controlled by us.

(6) Right to Non-Discrimination

The Company will not discriminate against California residents for exercising any of your rights under the CCPA. Unless permitted by the CCPA, The Company will not:

• Deny you goods or services;
• Charge you different prices or rates for goods or services, including through granting discounts or other benefits or imposing penalties;
• Provide you with a different level or quality of goods or services;
• Suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services; or
• Retaliate against an employee, applicant for employment, or independent contractor.

(7) Exercising Rights under the CCPA

To exercise your rights under the CCPA to access, delete, or correct your personal information as described above, please submit a verifiable consumer request to us by contacting us in the manner set forth in Section 8 (Contact Us).

Only you, or a person registered with the California Secretary of State that you authorize to act on your behalf, or a person who has power of attorney or is acting as your conservator may make a verifiable consumer request related to your personal information. You may also make a verifiable consumer request on behalf of your minor child.

The verifiable consumer request must:

• Provide sufficient information that allows The Company to reasonably verify that you are the person whose personal information The Company has collected or an authorized representative thereof (e.g. contact Enquiry ID, email address, etc.); and
• Describe your request with sufficient detail that allows The Company to properly understand, evaluate, and respond thereto.

6. Retention Period

The Company will retain your personal information for the period of time required to achieve the purpose of use set forth in this California Policy.

The retention period of personal data relies on (i) whether you continue to use The Company’s services, (ii) whether there are legal obligations that The Company must comply with, and (iii) whether there is a need to perform an agreement to which you are a party.

7. Processing of Personal Information of Children

Our services are not directed to and we do not knowingly collect personal information from anyone under the age of 13. If we learn that we have collected personal information from a child under the age of 13 without the consent of the child’s parent or guardian, we will delete it. We encourage parents with concerns to contact us in the manner set forth in Section 8 (Contact Us).

8. Contact Us

If you have any questions or comments about this California Policy or the ways in which The Company collects and uses your personal information or if you wish to exercise your rights under the CCPA, please do not hesitate to contact contact@kodansha.tech .

Privacy Policy Last Updated and Effective: March 25, 2025