Privacy Policy

Kirure Inc. (hereinafter referred to as “the Company”) hereby establishes this Privacy Policy (hereinafter referred to as “this Policy”) regarding the handling of Users’ personal information (as defined below) in relation to the poker calculation tool “drawplayer” (hereinafter referred to as “the Service”), which is operated and provided by the Company. This Policy applies to all individuals who use the Service (hereinafter referred to as “Users”). By using the Service, Users are deemed to have reviewed and agreed to the contents of this Policy. If you do not agree to this Policy, please discontinue use of the Service immediately. This Policy is established to properly manage Users’ personal information and respect their rights, and is intended to ensure the transparency and reliability of the services provided by the Company.

Article 1 (Definition of Personal Information)

“Personal Information” refers to “personal information” as defined in Article 2, Paragraph 1 of the Act on the Protection of Personal Information (hereinafter referred to as the “Personal Information Protection Act”). It includes any of the following:
- Information about a living individual, such as name, date of birth, address, telephone number, email address, workplace, or other descriptions, voice, images, or video recordings that can be used to identify a specific individual (including information that can be easily cross-referenced with other data to identify a specific individual).
- Data based on physical characteristics such as appearance, fingerprints, voiceprints, irises, DNA, etc., that can identify an individual (hereinafter referred to as “Biometric Information”).
- Information such as health insurance policy numbers, individual number (“My Number”), driver’s license numbers, or other codes used under laws and regulations to identify a specific individual.

Article 2 (Methods of Collecting Personal Information)

The Company directly collects personal information from Users in the following circumstances:
- When registering for the Service (including user name, email address, date of birth, password, and other information)
- When applying for Paid Services (including credit card information, address, phone number, and other information necessary for payment)
- When responding to inquiries from Users (including the content of inquiries and contact information)
- When participating in surveys, campaigns, or promotions (including responses and any provided information)
The Company may indirectly collect personal information about Users by the following means:
- Information provided by partner entities (e.g., payment service providers, advertising distributors, analytics service providers)
- Automatic information collection through cookies, log files, pixel tags, etc.
- Information collected via Google Analytics, used as an access analysis tool (managed in accordance with Google’s privacy policy)
Use of Cookies and Tracking Technologies
- For the purpose of improving the Service and enhancing the user experience, the Company uses cookies, pixel tags, and other tracking technologies. By doing so, the Company may automatically collect the following information:
  - IP address, browser type, device information, regional settings
  - Service usage, browsing history, click history
  Users can restrict or refuse the use of cookies by adjusting their browser settings, but please note that some features may not function properly as a result.
The Company uses Google Analytics, provided by Google, to analyze how the Service is used and to make improvements. Information collected through Google Analytics is managed in accordance with Google’s privacy policy. For details, please refer to Google’s privacy policy.
Important Notes
- The Company will manage the collected personal information appropriately and use it within the scope of the purposes of use.
- The information collected by the Company may include statistical data in a form that does not identify individual Users. Such data may not be subject to the Act on the Protection of Personal Information.

Article 3 (Purposes of Use of Personal Information)

Provision and Operation of the Service
- To enable Users to access the basic features of the Service and use Paid Services.
- To properly manage user registration and account information.
Handling Inquiries and Identity Verification
- To handle inquiries and requests from Users.
- To verify the User’s identity based on the inquiry details.
Notifications and Information Provision
- To notify Users about new features, updates, campaigns, etc. related to the Service.
- To provide important information about the Service (e.g., changes to the Terms, maintenance updates).
Billing and Payment Processing
- To appropriately handle billing and payment for the use of Paid Services.
Prevention of Fraud and Ensuring Security
- To prevent fraudulent or inappropriate use and security breaches in connection with the Service, and to ensure the safety of the Service.
Service Improvement and Analysis
- To analyze how Users use the Service in order to improve functions and enhance convenience.
- To compile statistical data in a manner that does not identify individuals, and use it for marketing activities and the operation of the Service.
Legal Compliance and Response to Violations of the Terms
- To fulfill legal obligations.
- To address violations of these Terms or laws by Users (e.g., identifying misuse, applying restrictions on the use of the Service).
Other Related Purposes
- For purposes reasonably related to and incidental to the purposes mentioned above.

Article 4 (Provision of Personal Information to Third Parties)

The Company will not provide Personal Information to any third party without the prior consent of the User, except in the following cases:
- When required by law: If provision is mandated by the Personal Information Protection Act or other laws and regulations.
- When necessary to protect life, body, or property: If obtaining the User’s consent is difficult and it is particularly necessary to protect someone’s life, body, or property.
- When necessary for the improvement of public health or the sound development of children: If obtaining the User’s consent is difficult and it is necessary for improving public health or promoting the sound development of children.
- When cooperation with national or local government agencies is required: If obtaining the User’s consent is difficult in order for a national or local government agency, or a party entrusted by such agency, to carry out administrative duties prescribed by law.
Notwithstanding the preceding paragraph, in the following cases, the entity receiving the information is not considered a third party:
- Outsourcing of operations: When the Company outsources part of its operations within the scope necessary to achieve the purposes of use (e.g., payment processing, data analysis, advertisement distribution). The Company will enter into an appropriate contract with such subcontractors and require them to manage Personal Information properly.
- Business succession: In the event the Company undergoes a merger, business transfer, or other form of succession. The successor shall handle Personal Information in accordance with this Policy.
- Joint use: When the Company jointly uses Personal Information with a specified party. In such cases, the Company will notify or publicly announce the following items in advance:
  - Items of Personal Information to be jointly used
  - Scope of entities jointly using the information
  - Purposes of use
  - Name or title of the person responsible for managing the Personal Information
If the Company provides Personal Information to a third party or obtains Personal Information from a third party, the Company will create and retain the necessary records for a certain period in accordance with the Personal Information Protection Act and other relevant laws and regulations.
When the Company provides Personal Information to a third party, the Company will conclude an appropriate contract and exercise proper supervision to ensure that the third party handles Personal Information appropriately.

Article 5 (Management and Retention Period of Personal Information)

The Company takes appropriate technical and organizational measures, including but not limited to the following, in order to securely manage Users’ personal information:
- Technical Measures
  - To prevent unauthorized access, data leaks, tampering, loss, or destruction, the Company applies security technologies such as data encryption, firewalls, and access controls.
  - The servers where personal information is stored are equipped with the latest security software, and the Company conducts regular vulnerability assessments.
- Organizational Measures
  - The Company appoints a person responsible for handling personal information and clarifies the management structure.
  - The scope of access to personal information is limited to what is necessary for business operations, and employees who have been granted access undergo periodic training.
The Company retains Users’ personal information only for the period necessary to achieve the purposes of use, and handles it appropriately under the following conditions:
- Once the retention period has ended, personal information is promptly deleted or anonymized.
- However, in the following cases, information may be retained for the necessary duration:
  - Where retention is required by law (for example, records that must be kept under the Commercial Code, Tax Law, etc.).
  - Where retention is necessary for dispute resolution or handling of claims.
Even if a User cancels or withdraws, the Company may retain that User’s personal information for a certain period under any of the following circumstances:
- Where there is a legitimate business need for the Company (e.g., preventing improper use, fulfilling legal obligations).
- Where the User’s consent has been obtained.
Data Processing and Deletion
- Once the retention period has ended, personal information is securely and completely deleted or anonymized under the Company’s management.
- If it is difficult to delete the data, the Company will convert it into a form in which individuals cannot be identified, and manage it appropriately as an alternative measure.
Users shall cooperate in maintaining the accuracy and up-to-dateness of their information, so that the Company can properly manage personal information and comply with the retention period.

Article 6 (Disclosure, Correction, and Deletion of Personal Information)

Right to Make Requests: In accordance with the Personal Information Protection Act and other relevant laws and regulations, Users have the right to request the following from the Company:
- Request for Disclosure of Personal Information: Users may request disclosure of the personal information held by the Company concerning them.
- Request for Correction, Addition, or Deletion of Personal Information: If there are errors in the personal information held by the Company, Users may request correction, addition, or deletion of such information.
- Request for Suspension of Use or Erasure of Personal Information: If the Company handles a User’s personal information beyond the scope of the intended purposes of use, or if the information was obtained by unlawful means, Users may request the suspension or erasure of such information.
Procedures for Making Requests
- If a User wishes to make any of the requests mentioned above, the User shall follow the method specified by the Company (e.g., submitting in writing or via email).
- In order to confirm the details of the request, the Company may require the User to submit the following information or documents:
  - Proof of identity (e.g., driver’s license, passport, health insurance card)
  - Detailed information related to the request
After confirming the User’s request, the Company will respond within a reasonable period. However, the Company may refuse to comply with the request under the following circumstances. In such cases, the Company will notify the User of the reasons:
- Where disclosure or compliance is not required under the law
- Where there is a risk of harming the life, body, property, or other rights and interests of another User or a third party
- Where there is a risk of significantly impeding the proper conduct of the Company’s business
- Where it would otherwise violate laws or regulations
Fees
- The Company may, within the scope permitted by law, charge fees for requests to disclose personal information.
- The amount of such fees and the method of payment shall be in accordance with procedures separately established by the Company.
Disclaimer
- Please note in advance that, as a result of corrections, additions, deletions, suspensions of use, or erasures requested by the User, there may be instances where the User can no longer use all or part of the Service.
- The Company will act based on the information provided by the User and shall not be held responsible for any delay or failure to respond if the information provided is inaccurate or insufficient.

Article 7 (Use of Cookies and Tracking Technologies)

Overview of Cookies and Tracking Technologies: The Company uses cookies, pixel tags, log files, web beacons, and other similar tracking technologies (hereinafter referred to as “Cookies, etc.”) for the purpose of enhancing the user experience, operating and improving the Service, and conducting marketing activities.
Purposes of Using Cookies, etc.: The specific purposes for which the Company uses Cookies, etc. are as follows:
- To enable Users to access the Service smoothly (e.g., maintaining the logged-in state).
- To analyze usage and browsing history in order to improve functionality and enhance usability.
- To provide advertisements or content tailored to the User’s interests or preferences.
- To detect security issues and prevent unauthorized access or misuse.
Use of Third-Party Cookies: The Company may use third-party cookies (e.g., Google Analytics, ad distribution services) to improve the Service and deliver advertisements. For details on how these third parties use cookies and handle collected data, please refer to the privacy policies of each service provider.
Methods for Managing or Refusing Cookies, etc.: Users can manage or refuse Cookies, etc. in the following ways:
- Change their web browser settings to disable or delete cookies.
- Use the cookie management tools provided by the Company to restrict or refuse their use.
- Use opt-out tools provided by third parties to stop tracking by specific advertising services. Note: If Users disable cookies, some features of the Service may not function properly.
Protection and Management of Data: The Company will manage data collected through Cookies, etc. appropriately by the following methods:
- Information collected via Cookies, etc. is properly protected in accordance with the Personal Information Protection Act and other relevant laws and regulations.
- Collected data is retained only for the period necessary to achieve the intended purposes.
User Rights: Users have the right to review information regarding the use of Cookies, etc. and to refuse or change settings at any time. If the use of Cookies, etc. affects the User’s personal information, the User may request details about such use.

Article 8 (Changes to This Privacy Policy)

The Company may change this Policy for the following reasons:
- To comply with amendments or enactments of relevant laws or regulations.
- To accommodate changes in the content or operational policies of the Service, or to address technical improvements.
- If the Company deems it necessary to protect the interests of Users and ensure appropriate information management.
2. In the event this Policy is changed, the Company will notify Users of the changes and their effective date in one of the following ways:
- Posting on the Service.
- Sending an email to the address registered by the User.
- Other methods deemed appropriate by the Company.
3. Effective Date of Changes
- Changes to this Policy will take effect at the time the revised Policy is posted on the Service or on the effective date specified by the Company.
- If the User does not agree to the revised Policy, the User shall cease using the Service before the effective date of the changes. If the User continues to use the Service after the changes, the User will be deemed to have agreed to the revised Policy.
If the Company makes changes that significantly affect Users (e.g., changes to the purposes of use of personal information, addition of new data collection items), the Company will take the following actions:
- Provide individual notice to Users and obtain explicit consent.
- If consent cannot be obtained, take measures to ensure that the relevant changes do not apply to those Users.
Impact on Users
- If the changes to this Policy affect Users, the Company will explain the changes in as clear a manner as possible.
- Users shall promptly perform any necessary settings or procedures required by these changes (e.g., reconfirmation of consent, opt-out settings).

Article 9 (Contact Information)

Scope of Inquiries: Users may contact the Company regarding the following matters related to this Policy and the handling of personal information:
- Questions about the content and scope of application of this Policy.
- Requests for the disclosure, correction, deletion, suspension of use, etc. of personal information.
- Any other opinions or requests concerning personal information protection.
Contact Information: For inquiries regarding this Policy and the handling of personal information, please contact the following:
- Business Name: Kirure Inc.
- Email Address: info@drawplayer.com
- Address: 2F-C, Shibuya Dogenzaka Tokyu Building, 1-10-8 Dogenzaka, Shibuya-ku, Tokyo 150-0043, Japan
Methods and Hours for Handling Inquiries
- In principle, inquiries are accepted via email. If you wish to make an inquiry by mail, please contact us by email in advance.
- We respond to inquiries during our business hours (Monday to Friday, 9:00 AM to 6:00 PM, excluding weekends and holidays).
- Depending on the content of the inquiry, it may take time to provide a response. Furthermore, specific requests will be handled in accordance with applicable laws and regulations.
4. Identity Verification and Conditions for Response
- If a User requests the disclosure, correction, deletion, or suspension of use of personal information, the Company may require the presentation of identity verification documents (e.g., driver’s license, passport).
- If the inquiry violates any law or this Policy, the Company may refuse to respond. In such cases, the Company will provide the reason to the extent reasonable.
5. Important Notes
- Personal information obtained based on the inquiry will be used only to the extent necessary for the relevant response, and will be appropriately processed once its purpose of use has been fulfilled.
- If the User designates a third party as their agent, the Company may request the submission of an appropriate power of attorney.