Last Updated:14thJan.

Privacy Policy

How we collect, process and protect your personal data

1. Overview

Kotoko Inc. and designated affiliates (“Kotoko”, “we”, “us” or “our”)respects your right to privacy and value the protection of your Personal Data. This Privacy Policy explains how we collect, process, store, share and protect your Personal Data when you use our products and services under the Bside brand including but not limited to the mobile application known as “Bside”, the PC application distributed via Steam under the name “Bside: DesktopMate”, the official website located at www.bside.zone, and any related features, content, or services (collectively, the “Services”).

The mobile and PC versions are separate products with different features. Certain account- and character-related data may be shared or synchronized across platforms to support a unified user account experience.

By accessing or using the Services, you acknowledge that your personal data will be processed as described in this Privacy Policy.

This Privacy Policy should be read together with our Terms of Service, which governs your access to and use of the Services. Capitalized terms not defined here have the meanings given in the Terms of Service.

Important: Before using the Platform or submitting any Personal Data to us, please review this Privacy Policy carefully. By using the Platform, you agree to the practices described in this Privacy Policy. If you do not agree to this Privacy Policy, you may not access the Platform or otherwise use our services.

2. Categories of Personal Data We Collect

The scope of Personal Data we collect depends on the functions of the Platform you use and how you use those functions. The purposes and types of Personal Data we collect are summarized below.

A. Personal Data You Directly Provide

  • Registration and Account Information: When you register for an account or log in to the Services, we may collect information such as your nickname or username, email address, password (stored in encrypted or hashed form), age or age confirmation information, mobile phone number (if provided), and third-party login identifiers. Account data is used solely for account creation, authentication, and service provision, and is not used for advertising profiling or sold to third parties.
  • Contact and Communications: When you contact us or communicate with our customer support, we collect the information you provide, including your name, contact details, and the content of your communications.
  • Marketing Communications: If you choose to receive marketing communications, we may use your contact information (such as email address or phone number) to send you information about our products and services. Where required by applicable law, we will obtain your consent before sending such communications.
  • Inquiries and Customer Service: Information you provide when submitting inquiries, including your name, contact details and communications with our customer service.
  • Surveys: We collect information you voluntarily provide when voluntarily participating in our surveys, feedback, requests or similar activities.


B. Data Generated During Platform Use

  • User-generated content: We collect content that you create, upload, or submit through the Services, including stories, descriptions, text, images, screenshots, and other materials;
  • Interaction and Content Creating: Where messaging or social features are available, we collect messages and communications exchanged through in-app messaging, group chats, or other social interaction features.
  • Character Creation and In-GameInteractions: Your creation of virtual characters and your interactions with characters or simulated environments (such as “Spaces”) may generate personal data reflecting gameplay behavior, creative preferences, and interaction patterns.
  • Social Network: The social network functions may generate personal data about your social connections and relationships through cultivated characters and shared profile information.

Interactions with virtual characters or OCs are conducted through automated or AI-powered systems and do not involve real human operators, unless explicitly stated otherwise.

C. AI-Generated Interactions and Content

Content generated through automated or artificial intelligence features, including text, images, videos, or events involving virtual characters. Logs or metadata necessary to provide, moderate, and improve AI-powered features. Certain user-generated content may include or be augmented by AI-generated elements produced by automated systems.

D. Payment and Transaction

When you make purchases through the Services, we collect transaction-related information such as purchase records, order numbers, transaction amounts, and purchase history. We may also maintain records of virtual items or virtual currency balances associated with your account.

We do not store complete credit card or payment card details. Payment information is processed directly by third-party payment service providers.

E. Data from Third Parties

  • Third-Party Login: If you choose to register or log in through third-party platforms (such as Steam), we may collect information provided by those platforms, such as your third-party nickname or user identifier, in accordance with your authorization.
  • Third-Party Payments are processed by third-party providers (such as Apple IAP, Google IAP). We receive confirmation of payment and transaction details but do not receive or store full payment card information.

F. Automatically Collected Data

When you access or use the Services, we automatically collect certain information about your device and usage, including:

  • Device identifiers, device type, operating system, and application version.
  • Log data such as IP address, access times, crash reports, and diagnostic information.
  • Some of this information may be collected through cookies or similar tracking technologies.
  • Platform Stability and User Experience: We collect data related to application operation and your online activities, such as login status, click data, device data, application identifiers, operating system information, and network information (e.g., IP address).

3. Purposes of Processing

We process personal data for the following purposes:

  • To provide, operate, and maintain the Services and user accounts;
  • To enable gameplay, AI interactions, messaging, social features, and user-generated content;
  • To process purchases and deliver virtual items or features;
  • To ensure safety, security, and compliance with applicable laws and platform rules;
  • To detect, prevent, and address fraud, abuse, or prohibited activities;
  • To analyze usage and improve the performance and functionality of the Services;
  • To communicate with users regarding service updates, support requests, or important notices.

4. How We Share Personal Data

We may engage third parties to process your Personal Data on our behalf to improve and maintain our services. We enter into strict confidentiality agreements with such parties and require them to process Personal Data in accordance with our requirements and applicable laws. We may also share your Personal Data in the following circumstances:

  • Business Changes: In the event of any change of control, merger, acquisition, reorganization, or liquidation, we will ask the new entity to continue processing your Personal Data in accordance with this Privacy Policy.
  • Legal Compliance: To comply with applicable laws, exercise or defend legal rights, orprotect vital interests.
  • Law Enforcement: To relevant law enforcement bodies, regulatory agencies, courts or other third parties where required by law.

Prior to sharing, where required by applicable laws, we may separately inform you of the third parties' details, processing purposes and types of Personal Data, and obtain your consent.

5. How We Protect Your Personal Data

We use appropriate technical and organizational measures to protect your Personal Data. The measures we use are designed to provide a level of security appropriate to the risk of processing your Personal Data.

Important: Please be aware that we cannot guarantee absolute security of the Internet. If you find that your Personal Data is breached, please contact us immediately using the contact details provided below.

In the event of any accident, force majeure event or other circumstances leading to the breach of your Personal Data, we will:

  • Make every effort to control the situation;
  • Promptly inform you of the cause and security measures taken;
  • Report to competent authorities as required by law;
  • Investigate the problem and take emergency measures.

6. How We Store Your Personal Data

A. Storage and Cross-border Transfer

  • Your Personal Data is saved in our database in the United States. For global operation needs, your Personal Data may be transferred to and stored in a jurisdiction different from yours, which may not provide the same level of data protection.
  • Under such circumstances, we take all necessary safeguards to ensure data security in transit and require adequate protection levels from recipients through appropriate data processing agreements and standard contractual clauses.

B. Retention Period

  • We store your Personal Data only to the extent necessary for proper business needs (providing services, complying with legal requirements), except as otherwise required by applicable laws.
  • When there is no business need or the retention time limit expires, we will delete or anonymize your Personal Data.

7. Lawful Basis for Processing (EU/EEA Users)

Our lawful basis for collecting and using Personal Data will depend on the specific data and context. The specific lawful basis on which we rely for each of the purposes which we process your Personal Data for is set forth below:

When choosing to use your data on the basis of our legitimate interests, we always use a balance test to weigh our interests against your interests or fundamental rights and freedoms.

If you would like information on the balancing test regarding the legal basis for data processing, please contact us using the contact details provided in the "Contact Us" section below.

8. Your Rights

We value the protection of your Personal Data. You have the following rights regarding your personal information:

A. Access Your Personal Data

You have the right to access the Personal Data we collect about you. For data you voluntarily provide (nicknames, usernames, account emails, profiles), you can view them on your personal page. You can also request a copy of your Personal Data by contacting us.

B. Correct Your Personal Data

If your Personal Data is inaccurate or incomplete, you have the right to correct it. For most personal information, you can make corrections within your personal page. For other data, contact us using the details below.

C. Delete Your Personal Data

You have the right to request deletion of your Personal Data, including your Bside account and related information.

To delete your account, please visit:

https://settings.bside.zone/account-deletion

This page provides clear instructions on how to request account deletion and explains what data will be deleted and any applicable data retention periods.

Note: After your account deletion request is confirmed, you will no longer be able to signin to or use Bside applications. Please make sure you understand the consequences before proceeding.

D. Opt-out of Marketing

You can exercise this right by clicking "unsubscribe" or "opt-out" options when registering or in marketing messages we send you.

E. File a Complaint

You have the right to file a complaint with the data protection authority about our collection and use of your Personal Data. Before filing a complaint, we hope you will first contact us with your concerns.

F. Withdraw Consent

If we process your Personal Data based on your consent, you may withdraw consent at any time. Withdrawal will not affect the lawfulness of processing carried out before your withdrawal.

To exercise any of these rights, please contact us using the information providedi n the "Contact Us" section below. We may need to verify your identity before responding to protect your information security.

9. Age Requirements

The Services are not intended for children under the age of 13. If you are under the age of majority in your jurisdiction, you may use the Services only with the consent and supervision of a parent or legal guardian.

Certain features, including AI interactions, messaging, and user-generated content tools, may be limited, modified, or unavailable for users identified as minors, depending on jurisdiction and platform requirements.

10. Updates to This Privacy Policy

We may update this Privacy Policy from time to time in response to changes in legal, technical or business developments. When we update our Privacy Policy, we will take appropriate measures to inform you, such as:

  • Email notification
  • Notice on our Website
  • In-app notice prior to the effective date

Before making material changes, we will ensure you can accept such changes as required by applicable laws. You can see when this Privacy Policy came into effect by checking the "Last Updated" date at the top.

If you continue to use any functions of the Website or applications after updates, you are deemed to have accepted the updated Privacy Policy.

11. Contact Us

If you have any questions or concerns about this Privacy Policy or our processing of your Personal Data, please contact us. We will review your question without delay and make a timely reply according to applicable laws.

Kotoko Inc.
200 Continental Drive, Suite 401, Room 434
Newark, DE 19713, United States
Email: media@bside.zone