privacy policy

Game & Co., Inc. (hereinafter referred to as "our company") will handle personal information of users (hereinafter referred to simply as "users") of "AMICIS" (hereinafter collectively referred to as "our service") provided by our company, our business partners (hereinafter referred to simply as "business partners" and collectively referred to as "you"), and other personal information acquired by our company, as follows:

In addition to this Privacy Policy, the Company may establish special handling of personal information related to users for individual Services (hereinafter referred to as "Individual Regulations"). In such cases, the Individual Regulations shall constitute part of this Privacy Policy, and in the event of any conflict between the two, the Individual Regulations shall take precedence.

In addition, we may change our privacy policy as necessary, so please be sure to read the entire text before using our services.

1. Acquired Information The information acquired by the Company in order to achieve the purposes of use set out in Section 4 (hereinafter collectively referred to as "Acquired Information") includes the following:

The following personal information (referring to "personal information" as defined by the Act on the Protection of Personal Information) is exemplified below:

Name, date of birth, gender, occupation (including job title), and other information that can identify a specific individual Address, telephone number, account information (email address, password, etc.), nickname, etc. used in connection with specific personal information Payment information such as credit card information, virtual currency and blockchain wallet addresses Hobbies, family composition, age, and other personal attribute information that is integrated with personal information Information for identity verification Information about the individual obtained in connection with the use and transactions of the Service Information related to the user's use and browsing of the Service, such as the content of the Service used by the user, the date and time of use and number of times, the user's online behavior when using the Service (including cookie information, access log information, and other usage information, as well as information on the user's communications, including device information, location information, IP address, browser information, browser language, etc.)
Information about the payment status of users and business partners regarding this service or business relationships. If users permit linking to external services such as social networking services when using this service, the ID used by the user in such external services and information that the user has permitted disclosure to the linked services through the privacy settings of such external services.

2. Method of collecting acquired information We collect acquired information in the following ways:

The user directly enters the information on this service. The user provides the information to us in person, by email, post, in writing, or by telephone (when answering the phone with the user, the call may be recorded in order to improve the quality of the response).
Collected when users use or browse our services. Collected indirectly from business partners and third parties.

3. Safety Management MeasuresIn order to prevent unauthorized access, theft, loss, destruction, falsification, damage, and leakage of all personal information (hereinafter collectively referred to as "Leaks, etc."), we have established the necessary regulations for the management of personal information, and have taken the necessary safety management measures as follows to properly manage personal information.In addition, when outsourcing the processing of personal information to a third party, we will enter into a contract that stipulates the protection of personal information, and will manage and supervise the third party to ensure that it is managed appropriately.

(1) Organizational Safety Control Measures We will appoint a personal information protection manager etc. in accordance with our internal regulations, clarify the employees in charge of each task that involves handling personal information, and strive to prevent leaks, etc., while also establishing a reporting and communication system in the event of any leaks, etc., or any violation of rules regarding the handling of personal information, or any signs thereof, being identified. We will also appoint a personal information protection auditor etc., and implement a system to confirm the appropriateness of the handling of personal information.

(2) Personnel safety management measures We will provide training to employees on important points to note regarding the handling of personal information. In addition, we will stipulate matters regarding the confidentiality of personal information in our work regulations, etc.

(3) Physical safety control measures
We will take various measures to prevent leaks, etc., such as controlling entry and exit using IC cards, protecting and managing electronic media containing personal information by assigning passwords to such media, storing paper media containing personal information in lockable cabinets, and disposing of documents containing personal information in a way that makes it difficult to restore them.

(4) Technical security control measures We will take various measures to prevent leaks, etc., such as limiting the information systems that can handle personal information databases, etc., and restricting the granting of access rights to such information systems, maintaining, managing, and periodically reviewing the systems, and granting and managing access rights to folders for each business that handles personal information.

(5) Understanding the external environment When handling personal information in a foreign country, we will understand the personal information protection system of that country and take appropriate measures for safety management. Please contact us for the specific names of foreign countries where we handle personal information.

(6) Response in the event of a leak, etc. In the unlikely event that a leak or other incident occurs with regard to personal information handled by our company, we will take appropriate measures, such as reporting to the supervisory authorities and notifying the individual in question, in accordance with the provisions of the law.

4. Purpose of Use of Acquired InformationWe will use Acquired Information appropriately within the scope necessary to achieve the purposes notified or published at the time of acquiring or collecting the Acquired Information, the purposes set forth in the Terms of Use, etc., or the following purposes.Furthermore, we may change such purposes of use to the extent that they are reasonably deemed to be related to the purposes of use prior to the change, and in the event of such changes, we will notify you, post a notice on the Service or on a website operated by our company, or make an announcement in an easy-to-understand manner.

<Information acquired from users of this service>

To verify your identity To contact you and provide information on various matters related to our Service To provide our Service To simplify the input of information required when registering as a user for our Service To share information between our Services applied for by the user To confirm your application for the email distribution service and send emails To confirm and deliver purchases related to our Service To make billing, payment, and confirmation related to our Service To send rewards for surveys, etc. in which you have cooperated To send prizes for sweepstakes, etc. in which you have entered To investigate and analyze the usage status of our Service To improve and refine our Service content to provide a better experience, or to develop new services To prevent fraudulent activities that interfere with the normal provision of our service (including discovering and notifying users who are violating the terms of use, etc., and investigating, detecting, preventing, and responding to fraudulent activities such as fraud and unauthorized access that abuse our service, etc.)
To customize the content of our service to suit users To survey satisfaction with our service To aggregate statistically processed information and publish it as survey results To provide information and notifications about our service, new services, and various other services To request cooperation in surveys and participation in various events, and to report the results, etc. To deliver or display advertisements from our company or third parties To deliver or display product information within services provided by our company or third parties To resolve problems in the operation of our service and to comply with laws and regulations

<Personal information related to our business partners (name, affiliation, contact information, etc.)>
For communication, consultation, ordering, settlement, and other transaction execution and management regarding transactions with our company. For managing business partner information. For preventing fraudulent activities that interfere with normal transactions. For providing information and notifications about our service, new services, and other various services. For resolving transaction-related problems and complying with laws and regulations.

<Personal information regarding applicants who apply for and participate in our recruitment activities>
To provide recruitment and hiring information, recruitment selection, and confirmation of application history To contact applicants and respond to inquiries from applicants To provide information about recruitment events and seminars run by our company To create statistical data to be used in formulating our future recruitment policy, etc. To resolve recruitment-related issues and comply with laws and regulations

<Personal information regarding our company's executives, employees, retirees, and their families (hereinafter collectively referred to as "employees, etc.")>
For notification and contact with employees, etc. For employment management of employees, etc. (payment of remuneration, performance of personnel and labor management, provision of welfare benefits, etc.) For health management of employees, etc. and ensuring an appropriate working environment For providing welfare services to employees, etc. and handling various insurance and other procedures For notifying and reporting to government agencies, etc. regarding employees, etc. For resolving employee-related disputes and complying with laws and regulations

5. Joint Use We may jointly use acquired information as follows:

Scope of joint users: Our group companies (please see here for details)

Purpose of use by users: To be used by our group companies for the same purposes as in the previous paragraph. To convey and hand over to the relevant company when there is an inquiry, application for use, or other request regarding products and services provided by our company or our group companies. For business management and internal management of our group.

Items of personal information to be jointly used: Name, date of birth, address, gender, telephone number, account information, nickname, etc., SNS account information, transaction details (including service usage status, purchase history, payment information such as credit card information and wallet address, information on payment status, etc.), etc.

Person responsible for managing jointly used personal information (Group representative)
Brave Group Inc. (For more information, please click here)

6. Provision of Acquired Information to Third Parties In the following cases, the Company will provide Acquired Information to third parties to the extent permitted by law.

When providing information on this service in order to provide this service, some of the acquired information may be made public on this service or provided directly to users to the extent permitted by law. In such cases, users shall use the disclosed or provided acquired information in accordance with the terms of use of this service and only to the extent necessary for using this service.

When providing personal information to delivery companies, payment agents, subcontractors, or other third parties for the purposes of product delivery, payment settlement, responding to inquiries from users, inquiries from our company to users, providing related after-sales services, etc.

When requested to provide acquired information by a court, administrative agency, supervisory authority, or other public institution based on laws and regulations.

When it is deemed necessary to provide information in order to resolve disputes with third parties or to protect the rights and interests of users of our service or third parties

When providing personal information to a third party to whom the Company entrusts such research and analysis in order to investigate and analyze the usage status of the Service, etc.

When providing personal information to third parties for the purpose of delivering or displaying advertisements for our company or third parties

When the Company determines that the provision of acquired information is necessary and obtains the user's consent

Other cases where provision to a third party is permitted by law.

7. Entrustment of the handling of acquired information to a third party We may entrust all or part of the handling of acquired information to a third party within the scope necessary to achieve the purposes of use set forth in paragraph 4. In such cases, we will thoroughly examine whether the party meets our company's selection criteria for contractors, and when entering into a contract, we will ensure that acquired information is managed appropriately.

8. Processing of Personal Information by Shopify The Service is hosted by Shopify. Therefore, any information you input or submit to the Service will be collected and processed by Shopify for the purpose of providing, maintaining, and improving the Service, including your usage history on the Service and other Shopify stores you use.

As part of Shopify's processing of your information, it may be transmitted to and shared with Shopify and its service providers, both domestic and international, including with third-party providers located outside your country of residence. We and Shopify will implement appropriate safeguards for these third-party transfers, such as the EU Standard Contractual Clauses (SCCs). Shopify is responsible for the processing of personal information collected in connection with these features and will also handle any rights you may have.

For information about Shopify's handling of personal information and how to exercise your rights regarding information processed directly by Shopify, please refer to the Shopify Consumer Privacy Policy and the Shopify Privacy Portal, in addition to our Group Shared Privacy Policy.

We may also use Shopify's advertising services to display personalized advertisements (targeted advertisements) based on your browsing history, etc. In this regard, you have the following rights depending on your place of residence.

(1) For customers residing in the EEA (European Economic Area) or the UK, the use of your information for the purpose of targeted advertising is based on your prior consent. You can manage (change or withdraw) this consent at any time via the cookie banner displayed when you visit the website of our service or the "Cookie Settings" link in the footer of the site.

(2) Customers residing in certain states of the United States (California, Colorado, etc.):
You have the right, subject to applicable privacy laws, to opt out at any time of us and Shopify "sharing" your personal information for marketing purposes or "targeting ads." If you wish to opt out, please follow the "DoNotSellorShareMyPersonalInformation" link in the footer of the site. We also apply the same opt-out policy when we receive Global Privacy Control (GPC) signals.

9. Personal Information We may incorporate information collection modules selected by us, such as Google Analytics, to collect cookies, device type, device identifier, browser type, referrer, IP address, and other advertising identifiers (hereinafter collectively referred to as "Personal Information") for the purposes of maintaining and protecting sessions to improve convenience, such as automatically entering email addresses when logging in to the Service, protecting security, and investigating and analyzing the usage of the Service and the effectiveness of advertising related to the Service.

These information collection modules collect personal information without including any information that can identify individuals, and the collected information is managed in accordance with the privacy policies and other regulations established by each information collection module provider. However, we may use personal information such as cookies obtained from information collection module providers by linking it with personal information already held by us.

If you do not want your data to be collected by Google Analytics or other information collection modules, please refuse data use in the manner specified by Google Inc. or each information collection module. However, if you prohibit the use of personal information such as cookies, you may be subject to restrictions such as being unable to use this service properly or being unable to reflect advertising settings that require personal information.

For information about Google Analytics' terms of use and privacy policy, please see the following website:

Google Analytics Terms of Use: https://www.google.com/analytics/terms/jp.html
Google Privacy Policy: http://www.google.com/intl/ja/policies/privacy/
Google Analytics Opt-out Add-on: https://tools.google.com/dlpage/gaoptout?hl=ja

10. Retention Period We will retain your acquired information to the extent necessary for the purposes set out in the "Purpose of Use of Acquired Information" above.

The criteria used to determine our retention periods include, but are not limited to, (i) the duration of our contractual relationship with you, (ii) whether we have a legal obligation to do so, and (iii) whether it is necessary for the performance of a contract to which you are a party.

11. Information of Underage Users If the user is a minor, the parent, guardian or guardian must agree to the contents of the "Privacy Policy" and the Terms of Use, etc., and must also give comprehensive consent to the user's use of the Service in accordance with the "Privacy Policy" and the Terms of Use, etc.

12. Improvements and Updates to the Privacy Policy We will review the operational status regarding the handling of user information, etc. as appropriate, and will revise this policy from time to time in response to changes in laws and regulations, business needs, etc.

If we change our privacy policy, we will notify you, so please be sure to check the latest privacy policy before accessing or using our services.

13. Procedures for Disclosure, Correction, Suspension of Use, etc. of Personal Information Disclosure, correction, deletion, or suspension of use (hereinafter referred to as "Disclosure, etc.") of personal information (including records of personal information provided to third parties) on this service will only be accepted upon request from the individual or their representative, in accordance with a method separately determined by our company. However, if our company is not obligated to do so under the Act on the Protection of Personal Information or other laws and regulations, if the same request is made repeatedly without justification, or if excessive technical work is required, we may not be able to carry out these procedures.

If you request the disclosure of personal information, you may be required to submit identification documents and pay a disclosure fee, as separately determined by our company.

14. Contact point for inquiries, comments, questions, complaints, or other inquiries regarding the handling of acquired information by our company, please contact the following point of contact.

[Contact point] (Group representative)
contact@bravegroup.co.jp
PMO Tamachi III 7F, 1-28 Shiba 4-chome, Minato-ku, Tokyo
Brave Group, Inc. Personal Information Desk

Supplementary Provision: Processing of Personal Information of Individuals Resident in the European Economic Area (EEA) or the UK This Supplementary Provision applies to the processing of personal information (meaning any information relating to an identified or identifiable natural person (who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person) of individuals resident in the European Economic Area (hereinafter referred to as the "EEA") or the UK, as provided for in the General Data Protection Regulation (hereinafter referred to as the "GDPR") or the UK General Data Protection Regulation (hereinafter referred to as the "UK GDPR"). This Supplementary Provision applies to individuals resident in the EEA or the UK.

1. Legal basis for handling personal informationIf you reside in the EEA or the UK, we will handle your personal information to the extent necessary to achieve the above-mentioned purposes of use, based on your consent to this Privacy Policy.In addition, if our handling meets either of the following requirements (1) or (2), we will also handle your personal information to the extent necessary to achieve the above-mentioned purposes of use.

(1) When the processing is necessary for the performance of a contract to which you are a party or in order to respond to your request prior to entering into a contract; (2) When the processing is necessary for the purposes of legitimate interests pursued by us or a third party (including, but not limited to, interests such as the provision of services by us);
Where it is essential for you to provide personal information, if you choose not to provide it, we will not be able to provide the relevant services to you.

You may withdraw your consent by contacting us via the contact details above. However, your consent regarding the collection, use, and provision of your personal information by us will remain valid until you withdraw your consent.

2. Transfer of Personal Information Outside the Territory Your personal information may be transferred to, stored or otherwise processed in a country or region other than your home country (including, but not limited to, Japan and the United States). Please be aware that the laws of such country or region may not provide the same level of data protection as in your home country. In such cases, we will take appropriate safeguards to protect your personal data in accordance with our legal obligations.

Where required under the GDPR or UK GDPR, we protect your personal information by using Standard Contractual Clauses when transferring your personal information outside the EEA or the UK. If you would like a copy of these Model Contractual Clauses, please contact us.

3. Rights under the GDPR or UK GDPR You have the right to request from us a copy of your personal information, to request correction, to request deletion or restriction of processing (suspension of use) of your personal information, and to request that we provide you with personal information that you have provided to us for the purposes of a contract or on the basis of your consent in a structured, machine-readable format.

You can also object to the processing of your personal information in certain circumstances, in particular where we are processing the information for direct marketing purposes.

However, these rights may be limited if, for example, fulfilling your request would reveal personal information of a third party, would infringe the rights of a third party (including ours), or we are legally required to hold it or have a legitimate interest in holding it. Relevant exceptions are contained in applicable privacy laws. We will make sure to inform you of any exceptions we rely on when fulfilling your request.

If you wish to exercise these rights, please contact us via the contact form. If your complaint is not resolved, you may also lodge a complaint with the EU data protection authority with jurisdiction over your place of residence, place of work, or the area where you believe the infringement occurred.

Supplementary Provision: Handling of Personal Information of Residents of California, USA This Supplementary Provision applies to the handling of personal information of residents of California, USA (meaning information that identifies, relates to, describes, references, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household; the same applies hereinafter in this Supplementary Provision) in accordance with the provisions of the California Consumer Privacy Act and the California Privacy Rights Act (collectively referred to as the "California Privacy Laws").

1. Information we collect For the purposes set out in "Purposes of use of collected information" above, we have collected the categories of personal information from you in the past 12 months, and will continue to collect the categories of personal information in the future.

Category Example Identifier Name, date of birth, gender, occupation (including job title), address, telephone number, account information (email address and password, etc.), nickname, hobbies, family composition, age Transaction information Credit card information, payment information such as virtual currency and blockchain wallet address Information regarding payment of usage fees, information regarding payment status for this service or business relationships

Internet or other electronic network activity information: Information related to the user's use and browsing of the Service, such as the content of the Service used by the user, the date and time of use and number of times, the user's online behavior when using the Service (including information on usage such as cookie information and access logs, information on the device used, location information, IP address, browser information, browser language, etc.)

Occupation or employment information: Department and company information (company name, address, telephone number)

2. Disclosure of Personal Information We may disclose your personal information to third parties for business purposes. When disclosing personal information to service providers or contractors for such purposes, we will enter into a contract with the service provider or contractor that describes the purpose and requires them to maintain the confidentiality of the personal information and to refrain from using the personal information for any purpose other than performing the contract.

In the past 12 months, we have shared or disclosed personal information with the following categories of third parties for a business purpose:

① Our group companies (please see here for details)

[Purpose of disclosure]
To use the information for the purposes described in "Purposes of Use of Acquired Information" within our group companies. To communicate and hand over to the relevant company when there is an inquiry, application for use, or other request regarding products and services provided by our company or our group companies. For business management and internal management of our group.

② Delivery companies, payment agents, business partners and other third parties [Purpose of disclosure]
For product delivery, payment settlement, responding to inquiries from users, inquiries from our company to users, and providing related after-sales services, to investigate and analyze the usage status of our services, etc.

3. Selling and Sharing Personal Information We have not sold or shared any personal information in the past 12 months.
For the purposes of this Supplementary Provision, "sale" means the disclosure of your personal information to a third party for monetary or other valuable consideration, and "sharing" means the disclosure of your personal information to a third party for cross-context behavioral advertising, regardless of whether monetary or other valuable consideration is received.

4. YOUR RIGHTS AND CHOICES UNDER CALIFORNIA PRIVACY LAW If you are a California resident, California privacy law provides you with specific rights regarding your personal information. Below we describe your rights under California privacy law and explain how to exercise them.

(1) Right to access certain information You have the right to request that we disclose to you certain information regarding our collection, sharing, disclosure, or use of your personal information. Upon receiving and confirming your verifiable request, we will disclose to you some or all of the following information:

① The categories of personal information we collect about you. ② The categories of sources of the personal information we collect about you. ③ Our business or commercial purpose for collecting, selling, or sharing that personal information. ④ The categories of third parties to whom we disclose, sell, or share that personal information. ⑤ The categories of personal information disclosed, sold, or shared with each third party. ⑥ The specific details of the personal information we collect about you.

(2) Right to Request Deletion You have the right to request that we delete any part of your personal information that we have collected from you and retained, except under certain exceptional circumstances. If we receive and confirm your verifiable request, we will delete your personal information from our records (and notify our service providers or contractors, as well as third parties to whom we have sold or shared your personal information, to do so), unless certain exceptional circumstances apply.
We may deny your request to delete information if retaining it is necessary for us or our service providers or contractors to:

(i) To complete the transaction for which we collected your personal information, to fulfill the terms of a warranty or a product recall made pursuant to federal law, to provide a product or service you have requested, to take steps reasonably anticipated by you within the context of our ongoing business relationship, or to otherwise perform a contract between you and us.
② To help ensure the security and integrity of your personal information to the extent that its use is reasonably necessary and proportionate to the purposes for which it is used.
③ To debug our products to identify and fix errors that interfere with existing intended functionality.
④ To exercise free speech, ensure your right to exercise free speech, or exercise other rights provided for by law.
⑤ To comply with the California Electronic Communications Privacy Act (California Penal Code Section 1546 et seq.).
⑥ To engage in public or peer-reviewed scientific, historical, or statistical research that complies with or conforms to all other applicable ethical and privacy laws, where the deletion of the information would likely render impossible or seriously impair your ability to complete the research, and you have provided your prior informed consent.
⑦ To enable only internal uses that are reasonably consistent with your expectations based on your relationship with us and that are consistent with the context in which you provided the information.
8) To comply with legal obligations.

(3) Right to request correction: You have the right to request that the Company correct any inaccurate personal information about you that it holds, taking into account the nature of the personal information and the purpose of processing it. Once the Company receives and confirms your verifiable request, it will make commercially reasonable efforts to correct any inaccurate personal information as instructed by you, in accordance with the provisions of the law.

(4) Right to Opt Out We have not sold or shared any personal information collected from you, and will not sell or share such information in the future.

(5) Right to Non-Discrimination: We will not discriminate against any California resident for exercising their rights under the California Privacy Act. Furthermore, except as permitted by the California Privacy Act, we will not engage in any of the following actions:

1) Refuse to provide you with products or services.
② Charging you different prices or rates for products or services, including by offering discounts or other benefits or imposing penalties.
③ Providing you with products or services of a different level or quality.
④ Suggest that you may receive products or services at a different price or rate, or of a different level or quality.

(6) Exercise Your Rights. If you wish to exercise your rights under California privacy laws, please contact us and make a verifiable request to us.
Only you, a natural person authorized by you to act on your behalf or registered with the California Secretary of State, your designated agent, or your guardian may make a verifiable request regarding your personal information. You may also make a verifiable request on behalf of your minor children.

A "verifiable claim" is
① You must provide sufficient information to allow us to reasonably verify that you are the subject of the personal information collected by us or an authorized representative.
② It must describe your request in sufficient detail to allow us to properly understand, evaluate, and respond to your request.

5. Handling of Personal Information of Minors Our services are not targeted at minors, and we do not knowingly collect personal information from or share personal information of minors. If we become aware that we have collected or shared personal information of minors in violation of this Privacy Policy without the consent of the minor's parent or guardian, we will delete that personal information. If you have any concerns, please contact us.

Revised on August 22, 2025