Welcome to Godachi！

1.INTRODUCTION

This privacy policy informs you of your choices and our practices regarding any personal information that we process about you. Your use of the websit ,mobile app or PC software or PC software, and other online services, including connected products (collectively the "Services") distributed by RIZ GARDEN LTD ("Godachi", "we" or "us").

If you do not agree with this privacy policy, you must not use the Services.

This Privacy Policy does not apply to any information collected by Godachi offline. Nor does it apply to websites, apps, or other online services maintained by our affiliates, or other companies or organizations to which we link but are not subject to Godachi's control.

If you have any comments, questions or complaints regarding the processing of your personal information, you can contact us at [email protected].

2.COLLECTION OF INFORMATION

Godachi makes Services that are fun and entertaining for a wide range of audiences. Some of our Services may target children under 13 years old or the age of consent as their primary audience. We call these child-directed Services. Other Services we offer may target the users above the age of consent as the primary audience, but they also target children. We call these mixed audience Services. Typically, when one of our Services is mixed audience, we collect the ages of our users to provide them with an age-appropriate experience. Finally, some of our Services do not target and/or are not intended for children. We call these general audience Services.

3.How We Use Your Personal Information

This section applies to users who have reached the age of 13 or the age not be defined as children under applicable local laws and regulations. We will use the information in the following ways and in accordance with the following legal bases:

Children's Protection

We take many special precautions to protect children's privacy. Generally, we define "children" as users under 13, but we adhere to local "child" definitions where the age of consent differs.

Except in limited circumstances authorized by law, we will not knowingly collect personal information (for example, full name, or phone number) from children without providing notice to and obtaining verifiable consent from a parent or legal guardian. We only collect some information (like IP address, device ID, OS, etc.) automatically exclusively to support the essential internal operations of our Services. We will not knowingly use these technologies to track user behavior or amass profiles of children. We use limited information from children located in the EEA exclusively to perform our contract with the child to provide the Services.

Within our app, which we consider mixed audience, we use Google's AdMob program to serve children contextual (not behavioral or targeted) ads. We notify Google that these ad requests are for children to ensure AdMob compliance with Children's privacy laws.

If you are a parent or guardian and believe we hold personal information about your child, wish to review or request the deletion of your child's information, or have questions about the information we collected from you as a parent or guardian, please contact us at [email protected]. If we have actual knowledge that we have collected an email address from a child in connection with a customer support inquiry, we will also delete the child's email address immediately upon responding to the request.

4.Sharing and Storage of Your Information

Information You Choose to Share

You have the option of sharing your personal information with the public or with third parties. For example: (1) sharing gameplay video, screen shots or game achievements with third-party platforms or the public through a "share" button on your game system; (2) displaying your real name or photograph within games; and (3) sharing personal information with others through chat, text, or communications features.

If you choose to "share" content or to otherwise post information from or via our Services to a third-party platform, that information (which may include your and other users' personal information, like username and profile photo) will become public and the third-party platforms may have access to information about you and your use of our Services. Likewise, other users may use these same features to share information about you. For the protection of your information, we recommend you do not use your real name and personal photo in our Service. We are not responsible for how you choose to share personal information with the public or third parties, or how third parties use the feature to share information.

Our Storage and Sharing of Your Personal Information

In addition to the personal information you actively choose to share, we also store your personal information in the course of providing Services and may share it with selected third parties when necessary, as detailed below:

We share your personal information with selected third parties in and outside your country, including:

• • third parties that provide services in support of the Services, please click here for more details
• • related group companies, with whom we share your personal information to the extent necessary to operate the Services. The transfers contemplated above are made pursuant to our contract with you.
• • law enforcement agencies, public authorities or other judicial bodies and organizations

We disclose information if we are legally required to do so, or if we have a good faith belief that such use is reasonably necessary to:

• • comply with a legal obligation, process or request;
• • enforce our terms of service and other agreements, policies, and standards, including investigation of any potential violation thereof;
• • detect, prevent or otherwise address security, fraud or technical issues; or
• • protect the rights, property or safety of us, our users, a third party or the public as required or permitted by law (including exchanging information with other companies and organizations for the purposes of fraud protection).

Some of the recipients of your personal data listed above are located in countries outside the EU/EEA that do not offer the same level of protection with regard to personal data as required in the EU/EEA and where there is no adequacy decision by the European Commission. In that case we will ensure an adequate level of data protection by appropriate safeguards, e.g. EU Standard Contractual Clauses. If you would like to obtain a copy of the safeguard that we use, please contact us at the contact details indicated below.

5.The Security of Your Personal Information

We are committed to maintaining the privacy and integrity of your personal information no matter where it is stored. Our group companies have information security and access policies that limit access to our systems and technology. We protect data through the use of technological protection measures such as encryption, and also take reasonable steps to assure that third parties to whom we transfer information will provide protections appropriate to that type of information. Your personal information will remain subject to our technical and organizational controls and our policies and procedures (including this Privacy Policy).

Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal information, we cannot guarantee the security of the information transmitted to our Services.

If we learn that your unencrypted personal information has been compromised by a data breach, we will notify you in time consistent with applicable laws.

6.Data Retention

As a general rule, we retain your personal information only as long as required to perform the Services or other purpose that was the reason for the collection of the information. The precise periods for which we keep your personal information vary depending on the nature of the information, why we need it and relevant legal or operational retention needs. We will retain most of your personal information as long as you use the Services (i.e., until account removal or deletion in accordance with your request or in accordance with our EULA) with the following exceptions:

• • Contact Information that is obtained as a result of you participating in our promotional activities will be retained during such activities as expressly designated in the corresponding activities;
• • Game-play video recordings will be uploaded to our servers and deleted within one month from the date of their creation;
• • For services that include chatting functions, the chatlog will be retained in our servers for a maximum of 100 items per user and deleted within one month from the date of their creation.

When destroying personal information, measures will be taken to make the personal information irrecoverable or irreproducible, and electronic files which contain personal information will be deleted permanently using a technical method which makes the files irreproducible.

In the event that the processing and retention period have terminated, but personal information is required to be retained continuously for other reasons including for archiving purposes such as a complaint or the reasonable prospect of a legal claim as prescribed under applicable laws, the relevant personal information will be stored and maintained separately from other types of personal information. If you require us to destroy your personal information before the end of its life cycle (as set out in the retention policy above), we will destroy your personal information in accordance with local laws).

7.Your Rights

You have certain rights in relation to the personal information we hold about you. Some of these only apply in certain circumstances (as set out in more detail below) and as provided. To exercise any of your rights, please contact us at [email protected].

Access

You have the right to access personal information we hold about you, how we use it, and who we share it with.

Portability

You have the right to receive a copy of certain personal information that you have provided to us and that we process about you. This comprises any personal information we process on the basis of your consent (e.g., gender information) or pursuant to our contract with you (e.e., game play statistics), as described in the section "How We Use Your Personal Information". You have the right to receive this information in a structured, commonly used and machine-readable format. You also have the right to request that we transfer that personal information to another party.

If you wish for us to transfer such personal information to a third party, please ensure you detail that party in your request. Note that we can only do so where it is technically feasible. Please note that we may not be able to provide you with personal information if providing it would interfere with another's rights (e.g., where providing the personal information we hold about you would reveal information about another person or our trade secrets or intellectual property).

Correction

You have the right to correct any personal information held about you that is inaccurate.

Erasure

You can delete your account, or remove certain personal information. If there is any other personal information you believe we process that you would like us to erase, please contact us as described above.

You may request that we erase the personal information we hold about you in the following circumstances:

• • you believe that it is no longer necessary for us to hold such personal information; or
• • you believe the personal information we hold about you is being unlawfully processed by us.

You can also exercise your right to restrict our processing of your personal information (as described below) while we consider your request.

We may need to retain personal information if there are valid grounds under data protection laws for us to do so (e.g., for the defense of legal claims or freedom of expression) but we will let you know if that is the case. Where you have requested that we erase personal information that has been made available publicly on the Services and there are grounds for erasure, we will use reasonable steps to try to tell others that are displaying the personal information or providing links to the personal information to erase it too.

Restriction of Processing to Storage Only

You have a right to require us to stop processing the personal information we hold about you other than for storage purposes in certain circumstances. Please note, however, that if we stop processing the personal information, we may use it again if there are valid grounds under data protection laws for us to do so (e.g., for the defense of legal claims or for another's protection). As above, where we agree to stop processing the personal information, we will try to tell any third party to whom we have disclosed the relevant personal information so that they can stop processing it too.

You may request we stop processing the personal information in the following circumstances:

• • you believe the personal information is not accurate for the period it takes for us to verify whether it is accurate;
• • you believe the processing we are doing is unlawful and you want us to restrict its processing;
• • you believe the personal information is no longer necessary for our purposes but you require it to be stored for the establishment, exercise or defense of legal claims; or
• • you would like to verify whether our legitimate grounds for processing the information override your interests.

Objection

You have the right to object to our processing of personal information about you, including the right to opt out of marketing communications we send you at any time - you may exercise these rights by contacting us as described above. For marketing methods including e-mails, you can also opt out directly by clicking the "unsubscribe" or "opt-out" link included in the e-mails we send you; if you wish to opt out of other forms of marketing, please contact us as described above.

8.Third-party's Links

Our Services may link to or use other content from the Internet, including content offered by third parties that we do not control and whose privacy and data collection practices may differ from ours. For example, we may link to social media sites or sites that sell our products. We encourage you to carefully review the privacy policy and End-User License Agreement of such third parties, as they are not covered by this Privacy Policy, and Godachi is not responsible for them.

You may be able to alter settings on your browser, device, or other software to block or partially block those third parties. Sometimes those settings may not be effective.

9.Changes to Privacy Policy

We encourage you to read through this Privacy Policy with care. From time to time, we might make updates by putting a new version on our website. Please check this page frequently to see any updates or changes to this policy. If we make any material changes, we will notify you through the Services.

10.Supplemental Terms - Jurisdiction Specific

This section supplements the information above and further describes how we collect, use, and disclose personal information about U.S. consumers who use our Services.

The section "Collection of Information" describes all sources of personal information we collected.

The section "How We Use Your Personal Information" describes the business and commercial purposes for collecting your personal information.

The section "Sharing and Storage of Your Information"describes the third parties with whom we share personal information and for what purposes.

At Godachi, we are focusing on creating outstanding games and increasing game experience, not selling information. Subject to your legal rights, we share the information we collect about you with the reliable third parties. We have shared the following categories of personal information to third parties for business and commercial purposes:

Please note, except in limited circumstances authorized by law, we will not knowingly collect personal information (for example, full name, phone number, or precise location) from children without providing notice to and obtaining verifiable consent from a parent or legal guardian. If you believe we might have any personal information from or about a child, please contact us at [email protected].

Sensitive Information

We do not collect any sensitive personal information or sensitive data.

Your Privacy Rights Under Applicable State Law

In addition to the privacy rights described in "Your Rights " above, you may have the following rights:

Right to Opt Out of Sale: You have the right to know whether we sell your data and to opt out of such sale if we do. However, we do not sell the personal information of our users.

Right to Opt Out of Sharing for Targeted/Behavioral Advertising: You have the right to opt out of the sharing of your personal information for purposes of targeted/behavioral advertising. However, we will not share the personal information of U.S. Residents under 18 years old for the purpose of targeted/behavioral advertising.

If you make a privacy request, we may require you to provide information and follow procedures so we can verify the request and your jurisdiction before responding. U.S. residents may confirm their identity through the Services if they hold an account with us. Otherwise, they will be asked to submit personal details such as name, email address, telephone number, or address as needed for the purpose of verifying the request.

The verification steps we take may differ depending on the request you make. We will match the information you provide in your request to information we already have on file to verify your identity. If we are able to verify your request, we will process it. If we cannot verify your request, we may ask you for additional information to help us verify your request.

Exercising the Right to Opt Out

U.S. residents may exercise their right to opt out by clicking the below link.

• emailing us at [email protected]

You may submit a request to opt out through an authorized agent. If you do so, we will follow the same verification procedures as described above for deletion and request to know about information collected.