Privacy Policy for Games

With U Co., Ltd. (the “Company”), develops, publishes and otherwise provides games and game-related services that can be used alone, with friends or through a social network, via the Internet and by way of stationary and mobile devices.


The Company is committed to protecting the privacy of Internet users who use the Company’s games and game-related services on stationary or mobile devices, whether accessed through, (i) the Company’s website or through a third-party website (the “Platform”), such as Facebook, in which the Company’s application runs, or (ii) an iOS or Android application that the Company provides (the “App”) through an application download service, such as App Store, Google Play or the like (each being an “Application Store”), (the “Services”). This Privacy Policy is intended to inform you of the ways in which information that is obtained through the Services is collected and used and the ways in which the Company will protect the personal information that you provide. By using the Services, you consent to the collection, use and transfer of your information in accordance with this Privacy Policy and the Terms and Conditions of Use for Games and our With U Cookies Policy. Therefore, the Company asks that you read this Privacy Policy before further using any of the Services. If you do not agree to this Privacy Policy, please do not use the Services.


This Privacy Policy sets out information on the following matters:

  1. Who Is Allowed to Use the Company’s Services
  2. Information That Is Voluntarily Provided to the Company
  3. The Company’s Use of Personal Information
  4. Accessing or Amending Personal Information; Opting Out and Discontinuing of Use
  5. Viewing Personal Information through Services
  6. Links to Third-Party Websites
  7. Where We Store and Process Your Information
  8. Cookies

If you have any questions or comments about this Privacy Policy, the practices of the Company’s website, or your dealings with the Company’s website, please email us at or contact us:


Email: (related to this Privacy Policy) privacy@withu.co.jp

(related to the Company’s website) gwy-support@gwithu.com

Mailing: With U Co., Ltd.

JR Tower Office Plaza Sapporo, 12 Fl.

Kita 5-jyo Nishi 2-chome, Chuo-ku, Sapporo

Hokkaido 060-0005 Japan

This document was last updated on October 24, 2014.


The Privacy Policy may be revised or amended from time to time. Each time you access the Services, you agree to be bound by the most recent Privacy Policy then in effect, which is posted for your review. If the Company makes any material changes to this Privacy Policy, the Company will notify you of those changes by posting them through the Services or other notification, including when those changes will become effective. Your continued use of the Services after any changes to this Privacy Policy will constitute your acceptance of and agreement to such changes. Please refer to this Privacy Policy regularly so that you will always know what information the Company gathers, how the Company might use that information, and whether and how the Company might disclose that information to others.


This Privacy Policy is governed by the laws of Japan without regard to its conflict of laws principles. You and the Company agree to submit to the exclusive jurisdiction of the Sapporo District Court or Sapporo Summary Court in Hokkaido, Japan, and waive any jurisdictional, venue or inconvenient forum objections to such court.

1. Who Is Allowed to Use the Company’s Services

The Company’s Services may only be used by individuals who are at least 13 years of age. If you are not at least 13 years old, you must stop using the Services immediately. The Company does not solicit or knowingly collect personal information from persons under the age of 13. To the extent that the Company inadvertently collects personal information from persons under the age of 13, the Company will take immediately expunge such information from the Company’s records.

2. Information That Is Voluntarily Provided to or Collected by the Company

The decision to supply your personal information is yours. By and through the Platform or an Application Store or otherwise, the Company may collect information that is voluntarily provided by users of the Services, including, but not limited to, name, gender, locale, age range, email address, user ID for the Platform, friends registered in the Platform, purchase information for in-game currency, image information, and other personal information (collectively, “Personal Information”) in accordance with the Terms & Conditions of Use and this Privacy Policy.


In addition, the Company may collect (i) device data: the data regarding the device or any computer you may use to download or stream a copy of the App onto your device (such information is referred to as “Device Data”), including, where available, the device's or computer's unique device identifiers, operating system, browser type and mobile network information, for system administration and to report aggregate information to our advertisers; and (ii) log data: the Company’s servers automatically record certain information about how a person uses the Services (such information is referred to as “Log Data”), Log Data may include information such as a user’s Internet Protocol (IP) address, browser type, operating system, the web page that a user was visiting before accessing the Services, the pages or features of the Services to which a user browsed and the time spent on those pages or features, search terms, the links on the Services that a user clicked on and other statistics. The Company may associate Device Data and Log Data with your Personal Information and will treat the combined information as Personal Information in accordance with this Privacy Policy for as long as it is combined.


Any Personal Information sent to, or collected by, the Company will be used only for the purposes explained in the Services or this Privacy Policy.

3. The Company’s Use of Personal Information

The Personal Information is maintained by the Company and may be used by it and, only to the extent necessary to perform the purposes explained in the Services or this Privacy Policy, its affiliated companies (which means our subsidiaries, parent companies, joint ventures and other corporate entities under common ownership. The same shall apply hereafter), and their respective agents and partners in accordance with this Privacy Policy. The Company collects, stores and uses Personal Information for the sole purpose (“Purpose of Use”) of (a) enhancing your gaming experience and providing you with games and related services solely in connection with the Services; (b) the Company or its affiliated companies’ marketing, promoting and advertising their products; (c) enforcing the Services’ Terms & Conditions of Use; and (d) responding to claims that any content violates the rights of third parties. The Company may change the Purpose of Use at any time to the extent which is reasonably considered by the Company to be related to and compatible with the Purpose of Use before the change. If the Company changes the Purpose of Use, the Company shall post changes through the Services and make changes to this Privacy Policy as appropriate.


The Company may use Personal Information beyond the scope of the Purpose of Use without notice to you and without your consent in cases where (i) applicable laws and regulations require the Company to so use the Personal Information, (ii) it is impracticable to obtain your consent to so use the Personal Information and it is necessary to protect and defend the rights, property or safety of the Company, its affiliates, other users of the Services, or the public, or (iii) it is necessary to so use the Personal Information for cooperating with any relevant public authority in executing its affairs as prescribed by applicable laws and regulations and obtaining your consent is likely to impede the execution of such affair.


The Company will not sell, exchange or otherwise distribute your Personal Information to unaffiliated third parties without your consent, except to the extent required by applicable laws and regulations, or as follows:

  • The Company may enter into agreements with other companies and individuals to perform functions or services on its behalf. As a result, depending on the nature of the engagement, such other companies and individuals may have access to Personal Information, within the scope of the Purpose of Use, needed to perform their functions, but they will be restricted from using the Personal Information for purposes other than providing services to the Company and will ensure that your Personal Information is treated securely and in accordance with this Privacy Policy.
  • In the event that the Company transfers or merges its business with another company or entity, or buys any company, entity or business, Personal Information may be transferred to such other company or entity, or any prospective buyers or sellers of such company, entity or business.
  • The Company may share your Personal Information if (i) it is impracticable to obtain your consent to so distribute your Personal Information and it is necessary to protect and defend the rights, property or safety of the Company, its affiliates, other users of the Services, or the public, or (ii) it is necessary to so share the Personal Information for cooperating with any relevant public authority in executing its duties as prescribed by applicable laws and regulations and obtaining your consent is likely to impede the execution of such duties.
  • The Company may share your Personal Information with credit reference agencies for the purpose of assessing your credit score where this is a condition of us entering into a contract with you.

Our collection, use, and disclosure of anonymous or aggregated information (which is information about our users that does not allow them to be personally identified) are not subject to any of the restrictions in this Privacy Policy.


The Company uses Log Data to administer the Services, and analyzes (and may engage third parties to analyze) this information to improve and enhance the Services by expanding their features and functionality and tailoring them to our users’ needs and preferences. The Company may use a person’s IP address to fight spam, malware and identity theft. The Company also uses the IP Address to generate aggregate, non-identifying information about how the Services are used.

4. Accessing or Amending Personal Information; Opting Out and Discontinuing of Use

Users have the right to access their Personal Information. Further, users may seek to amend the Personal Information held by the Company on the grounds that the Personal Information so held is inaccurate, in which case the Company will, except in cases in which special procedures are prescribed by applicable laws and regulations for such amendment, promptly conduct the necessary investigation within the scope of the Purpose of Use and, on the basis of the results thereof, amend the Personal Information so held and notify the relevant third parties to which the related Personal Information is distributed (if there are any such third parties) of such amendment.


Users may opt out from receiving promotional and other communications from the Company. The Company may still email or communicate with a user from time to time if the Company needs to provide you with information or if the Company needs to request information from a user with respect to a transaction initiated by the user or for other legitimate non-marketing reasons. Changes to users’ email contact preferences may take up to ten (10) business days to take effect.


Where the Company is requested by a user to erase or discontinue using or distributing such Personal Information of the user so held on the grounds that such Personal Information is being used outside the scope of the Purpose of Use, has been acquired by deception or other wrongful means, or has been distributed to a third party in violation of Section 3, and where it is found that the request has a valid reason, the Company will promptly erase or discontinue using or distributing such Personal Information to the extent necessary to address such reason.


Any request in connection with any of these activities must be submitted in writing or by email to:

With U Co., Ltd.

Email: privacy＠withu.co.jp

Mailing: JR Tower Office Plaza Sapporo, 12 Fl.

Kita 5-jyo Nishi 2-chome, Chuo-ku, Sapporo

Hokkaido 060-0005 Japan


The Company may retain an archived copy of your records as required by law or for legitimate business purposes. We also reserve the right to use any aggregated or anonymous data derived from your Personal Information.

5. Viewing Personal Information through Services

Users’ Personal Information may be able to be viewed by other users when using the Services if such users allow their Personal Information to be so viewed by adjusting their user security settings. Users who make their Personal Information capable of viewing by other users by adjusting their user security settings are deemed to have given express permission to other users to view their Personal Information. Such a feature is not an indication that the Company endorses or encourages users to view the Personal Information of other users. Furthermore, the Company prohibits any user from using Personal Information of other users in any manner whatsoever except for the sole purpose of utilizing the Company’s Services. The Company recommends that users employ caution to ensure that their security settings allow only those who are trustworthy to view their Personal Information. The Company is not responsible for providing additional protection in this regard.

6. Links to Third-Party Websites

The Services may be provided through the Platform or Application Store, or the Company may provide links to the Platform or Application Store, but only as a convenience to the Services’ users. The Platform or Application Store are not under the Company’s control. The provision of Services through the Platform or Application Store or the inclusion of a link is not necessarily an endorsement by the Company of the Platform or Application Store. The Company is not responsible for the privacy practices or the contents of the Platform or Application Store or any link contained in the Platform or Application Store. Any Personal Information provided through the Platform or Application Store will occur on the Platform or Application Store alone, and the Personal Information will be collected exclusively by that third party that provides the Platform or Application Store and will be controlled by its privacy policy alone. Users that gain access to the Services from the Platform or Application Store must first read and agree to comply with the terms of use, privacy policy and other rules and guidelines of the Platform or Application Store prior to accessing the Services. You understand, acknowledge and agree that all access to and use of any such third party website by you shall be at your own risk.

7. Where We Store and Process Your Information

The information that we collect from you may be transferred to, and stored at, destinations outside the European Economic Area ("EEA") such as Japan and the United States of America. We may use the storage facilities of third party suppliers (such as Amazon Web Services) for the purpose of storing your information and these facilities may also be located outside the EEA. Your information may also be processed by staff operating outside the EEA who work for us or for one of our suppliers (such as Amazon Web Services) for the purposes set out in this Privacy Policy. By submitting your information on the Service, you agree to such transfer, storing or processing.

8. Cookies

The Company use cookies on the websites used to provide the Services to distinguish you from other users of the Services. This helps the Company to provide you with a good experience when you use the Services and also allows us to improve the Services. For detailed information on the cookies the Company use and the purposes for which we use them, see our cookies policy http://www.gwithu.com/legal/cookie.html.


EFFECTIVE AS OF: February 14, 2013

LAST MODIFIED AS OF: October 24, 2014


©With U Co., Ltd.

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