Overview

Kotoko Inc. and designated affiliates ("we" or "Bside") respects your right to privacy and value the protection of your Personal Data. This Privacy Policy explains how we collect, process and protect your Personal Data when you use Bside's website (www.bside.zone) or applications made available by Kotoko (including the applications known as "Bside" or other video games as Kotoko may publish), and how you can exercise your rights to Personal Data protection.

"Personal Data" in this Privacy Policy refers to all information in relation to an identified or identifiable natural person, including nicknames, email address, passwords, chat history, social account information, etc., excluding anonymized information.

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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.

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This Privacy Policy covers the following topics:

• What types of Personal Data do we collect and our purposes
• How do we share and entrust the processing of your Personal Data
• How do we protect your Personal Data
• How do we store your Personal Data
• Lawful basis for processing Personal Data (applicable to users located in the EU/EEA)
• Your rights
• How do we update this Privacy Policy
• How to contact us

1. What Types of Personal Data We Collect

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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 Login: When you register an account, we collect your nickname, age, password, email or mobile phone number to help you complete the registration and login process.
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Contact and Marketing: We may use your contact information (email address, cell phone number) to send you information about products and services that may be of interest to you. Where required by law, we will obtain your consent before sending marketing messages.
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Inquiries and Customer Service: Information you provide when submitting inquiries, including your name, contact details and communications with our customer service.
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Surveys: Information you provide when voluntarily participating in our surveys.

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B. Data Generated During Platform Use

Interaction and Content Creating: Your interactions with characters, including conversations and storylines, may generate personal data about your interests, beliefs, and relationships.
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Character Creation and Environment Interaction: Your establishment of AI characters ("Biibits") and interactions within simulated environments ("Spaces") may generate personal data relating to behavioral patterns, creative preferences, and social affinities.
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Social Network: The social network functions may generate personal data about your social connections and relationships through cultivated characters and shared profile information.
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Payment and Transaction: We collect payment amount, payment method, order number and other information to complete payment and transaction processes for various props and digital assets.
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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).

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C. Data from Third Parties

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Third-Party Login: You may register and sign in through third-party platforms (e.g., Steam). We collect your third-party nickname and Open ID when you consent to this registration method.

Third-Party Payments: Our payment method uses In-App Purchase (IAP) and integrates third-party payment channels (e.g., Stripe). Payment information such as credit card details is stored by the third-party provider.

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D. Automatically Collected Data

When you visit our Platform, we automatically collect certain Personal Data about you or your device, including IP address, device type, unique device identification numbers, browser type, broad geographic location, visit time, and content viewed.
Some of this data may be collected using cookies and similar tracking technology.

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Age Requirement: If you are under 13 years old, you are not authorized to register. If you are between 13 and 16, please get permission from your parent or guardian to use the Platform.

2. 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, or protect 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.

3. 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.

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

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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

4. 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.

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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.

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5. 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.

6. 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.

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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.

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C. Delete Your Personal Data

You have the right to request deletion of your Personal Data, including your Bside account and related information. You can do this through your personal page or by contacting us.

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Note: After requesting account deletion, you will no longer be able to sign in or use Bside applications, so please decide carefully.

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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.

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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.

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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 provided in the "Contact Us" section below. We may need to verify your identity before responding to protect your information security.

7. 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:
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• Email notification
• Notice on our Website
• In-app notice prior to the effective date
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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.

8. 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