AIDIS Inc., a Japanese corporation (the "Company," "us," "we"), thanks you (the "User") for your interest in our application, LAST CLOUDIA, our online gaming services and such other activities, products, services and content that we may offer from time to time (collectively, the "Services").

DISCLAIMER
The User is able to access the Services without the submission of any Personal Information (defined below). As a result, the Company does not knowingly collect any Personal Information from the User. If the Company unknowingly receives, through any means, any Personal Information of the User, the Company will handle the Personal Information in accordance with the terms of this policy (the "Privacy Policy"), as described below.

Article 1 (Handling of Personal Information)
The Company acknowledges the importance of Personal Information, and shall handle the Personal Information of the User acquired in connection with the User’s use of the Services provided by the Company in compliance with applicable laws and this Privacy Policy.

Article 2 (Personal Information)
Under this Privacy Policy, "Personal Information" is defined as any information that identifies an individual or could be used to identify an individual alone or in combination with other information. Personal information may include, but is not limited to: a person’s name, username, identifier, address, telephone number, credit card number, and e-mail address.

Article 3 (Acquisition Methods)
The Company shall obtain Personal Information from the User using proper and customary methods, without using deception or other illegal methods.

Article 4 (Purpose of Use)
The Company shall use the obtained Personal Information within the scope of purposes of use that are clear from the circumstances of acquisition. Company will not use Personal Information for any other purpose, except when agreed to by the User or when the Company is legally mandated to do so.

As a result, the Company may disclose the User’s Personal information for purposes of use that include, but are not limited to the following:
(1) Provision, maintenance, and improvement of the Services;
(2) Calculation of the billing amount, billing, refunds, and related paperwork;
(3) Advertising or promotion by the Company or a third party;
(4) Information and notifications on the Services and new services related to the Services;
(5) Responses to User inquiries;
(6) Surveys, statistics, and analysis;
(7) Sales activity, orders, business contacts, exercising rights and fulfilling obligations;
(8) Administration such as human resources, labor management and welfare, business contacts;
(9) Employment selection and joining procedure at the time of employment;
(10) Sharing of information with the Company’s subsidiaries or affiliates;
(11) The Company is acquired by or merged with a third party entity or the Company sells a part of its business to a third party;
(12) When required by law; and
(13) Other uses incidental to the uses in the preceding items.

In cases where the Company makes changes to the purposes for use in the preceding paragraph, the Company shall notify the User or make an announcement using a method separately established by the Company.

Article 5 (Disclosure to Third Parties)
The Company will not disclose Personal Information to third parties, except for, when agreed upon by the User, when the Company is legally mandated to do so or when disclosure of Personal Information falls under one of the following items:
(1) Disclosure to the Company’s director/employee or indirect subsidiaries or affiliates who are obligated under an agreement, to manage Personal Information in a manner that is consistent with this Policy;
(2) Disclosure to a financial institution, credit card company, collection agency, operator of application platform, or other business that performs settlement or acts as an agency in order to settle payments or other monies due to the Company;
(3) Disclosure to a third party as a linkage partner in order to use an external linkage service using various social media accounts (LINE, Twitter, Facebook, etc.) or Google account, when providing the Services;
(4) Disclosure to a contractor who is obligated under an agreement to manage Personal Information in a manner that is consistent with this Policy;
(5) Disclosure in connection with the sale of the Services, a portion of the Services or certain stock and/or assets, or a corporate merger, consolidation, restructuring, or other corporate change including, without limitation, during the course of any due diligence process; and
(6) Disclosure is requested by a law enforcement, judicial, administrative, or regulatory agency and Company believes in good faith that the law requires disclosure or that disclosure is necessary to protect or enforce the rights, property, safety, or security of Company or others.

Article 6 (Outsourcing of Personal Data)
The Company may outsource the Service in whole or in part, and disclose necessary Personal Information to the third party contractor so that it can perform the Service smoothly to achieve the purpose of use. When outsourcing the Services, the Company will supervise the contractor as necessary and appropriate, including supervision of subcontractors.

Article 7 (Secure Management, etc.)
The Company will update or delete your Personal Information upon your request, and delete applicable Personal Information when it is no longer needed for the purposes they were collected.

The Company has appointed a privacy officer and has put in place the appropriate measures for the secure management of the Personal Information of the User in order to protect against leaks, loss, or damage to the User’s Personal Information, however, due to the inherent open nature of the Internet, we cannot ensure or warrant the security of any information provided online.

We restrict access to your Personal Information to our employees, contractors and suppliers who need to know that information in order to process it on our behalf or to provide our Services to you.

Our employees, contractors and suppliers are bound by confidentiality obligations and may not use the information for any unauthorized purpose. The Company will ensure that the need for proper handling of Personal Information is thoroughly communicated to all employees, that proper training is provided, and necessary and appropriate supervision is given.

The Company may provide some Personal Information to external contractors in the course of carrying out business, such as providing the Services. In such cases, we will select a third party that has the appropriate security control measures in place regarding Personal Information, and will provide the necessary and appropriate supervision.

Article 8 (Commitment to the Privacy of Minors)
Protecting the privacy of minors is especially important to the Company. The Company does not knowingly collect any Personal Information of minors. The User, by accessing or using the Services, acknowledges that they are of legal age to form a binding contract or that they are entering into this contract with the consent of their parent or guardian. If we learn that Personal Information of a minor has been inadvertently collected, we will take the appropriate steps to delete this information. If you are a parent or guardian and discover that a minor for which you are responsible has provided their Personal Information to us without your consent, then you may alert us by contacting us at info@aidis.co.jp and request that we delete such minor person’s Personal Information from our systems.

Article 9 (Disclosure, Correction, Stopping Use, etc.)
If the User requests disclosure, correction, or removal of the User’s Personal Information, by sending a request to info@aidis.co.jp, the Company shall promptly comply with such requests, except for when mandated by applicable law. Note that Company's fulfillment of a User’s request to remove personal data may not ensure complete or comprehensive removal (e.g., if the content or information has been captured or reposted by another User).

Article 10 (Changes to the Privacy Policy)
The Company may make changes to the Privacy Policy without the prior agreement of the User when it deems it necessary.

In the event the Company makes changes as provided for in the preceding paragraph, the Company will promptly notify Users by posting a notice on its website. After the Company makes changes to the Privacy Policy and notifies Users per the preceding sentence, continued use of the Services by the User will be deemed acceptance of the updated Privacy Policy.

Article 11 (International Users)
Please note that we may store or process your Personal Information outside of your jurisdiction. The physical storage of your Personal Information may span multiple jurisdictions or countries and the governments, regulators, courts or law enforcement authorities in those jurisdictions or countries may be able to obtain disclosure of your information through applicable laws. Your use of the Services or your submission of any Personal Information to us will constitute your consent to the transfer of your Personal Information outside of your jurisdiction, which may provide for different data protection rules than those in your own jurisdiction.

Article 12 (Do Not Track Requests)
Because there currently is not an industry or legal standard for recognizing or honoring Do Not Track (DNT) signals, Company does not respond to them at this time.

Article 13 (Inquiries)
The Company regularly reviews its compliance with this Privacy Policy. When the Company receives a formal written complaints, it is our policy to contact the User regarding their concerns. We will cooperate with the appropriate regulatory authorities, including local data protection authorities, to resolve any complaints regarding the transfer of Personal Information that cannot be resolved between the Company and the User.

If you have any questions about this Privacy Policy, please feel free to contact us through the Services or write to us at: AIDIS Inc., Attention: Privacy Officer, 6F, Sumitomo Fudosan Aoyama-Dori Building, 1-7-7 Shibuya, Shibuya-ku, Tokyo or at info@aidis.co.jp.

Last Updated on 5 March 2020