PenniPri: Penniless Princesses

Privacy Policy

Ullucus Heaven Inc. (referred to as "we," "us," or "our") sets forth this Privacy Policy (this "Policy") regarding the handling of personal information of users (referred to as "Users," "you," or "your") in connection with the service "PenniPri: Penniless Princesses" operated and provided by us (the "Service").

1. Information We Collect

We collect the following information in providing the Service:

(1) Information Obtained Directly from Users

• Email address (at the time of inquiry)
• Content of inquiries
• Player name
• Data transfer password

(2) Information Collected Automatically

• Mobile device identifiers (Advertising identifiers: IDFA / AAID, device IDs, etc.)
• OS version and device model name
• Player ID
• Operation history and play logs within the Service

(3) Payment-Related Information

• Purchase information provided through app stores or payment processors (purchase date/time, amount, item names, etc.)
• Note: Credit card information is managed by payment processors; we do not directly acquire or retain such information.

2. Purpose of Use

We use the information we collect for the following purposes:

• To respond to inquiries and perform identity verification
• For user authentication and management of Users
• To provide, maintain, protect, and improve the Service
• To deliver and optimize rewarded advertisements
• To prevent unauthorized use (cheating, etc.)
• To notify Users of important announcements regarding the Service
• To fulfill obligations based on laws, regulations, or the Terms of Service

3. Legal Basis for Processing (For Users Residing Outside Japan)

We process personal information based on the following legal bases:

• Consent of the User
• Performance of a contract
• Our legitimate interests (improving Service security, maintaining the Service through advertising, etc.)
• Compliance with legal obligations

4. Disclosure to Third Parties and Service Providers

We do not provide personal information to third parties except in the following cases:

• With the User's consent
• Based on laws and regulations
• When necessary to protect life, body, or property

We may outsource certain operations to external contractors and share information within the scope necessary to achieve the purpose of use, including:

• Payment processing
• Server operation
• Customer support
• Advertisement distribution and analysis

Ad distribution service providers may process User information based on their own privacy policies.

Furthermore, for the purpose of researching Service usage trends, efficient operation, prevention of fraud, and advertising to Users, we may use information collection modules from the following third parties. Please also refer to the privacy notices of each company.

Advertising SDKs:

• Adjust GmbH (Adjust SDK)

https://www.adjust.com/terms/privacy-policy

App Usage and Push Notification Analysis:

• Google LLC (Google Firebase)

https://policies.google.com/privacy

5. International Data Transfer

The Service is operated from Japan. User information may be transferred to servers in Japan or to overseas contractors. We endeavor to ensure that appropriate protective measures are taken in the destination country in accordance with applicable laws (such as the PDPA in Singapore).

6. Data Retention Period

We will not retain User personal information longer than necessary to achieve the purpose of collection, unless there is another legal basis for such processing (e.g., fulfillment of legal obligations). After the retention period ends, your personal information will be deleted or anonymized in a secure manner.

7. User Rights and Opt-Out

Users may have the following rights based on the laws of their place of residence:

• Access to personal information
• Correction
• Deletion
• Suspension of use
• Request for a copy of data

Upon request from a User or their representative, we will respond in accordance with the law without undue delay. For inquiries regarding these requests, please contact the point of contact in Section 12.

Additionally, you may opt-out of ad tracking at any time by changing your Device settings (e.g., the "Allow Apps to Request to Track" setting on iOS, or "Opt out of Ads Personalization" on Android).

8. Information for California Residents (CCPA/CPRA)

Disclosure of Personal Information Categories

Categories collected in the past 12 months:

• Identifiers
• Commercial information
• Internet activity information
• Device information

Personal information in each of the above categories is used within the scope of the purposes described in Section 2.

Sale and Sharing

We share User personal information, such as device identifiers, with ad distribution providers for the purpose of providing rewarded advertisements (Sharing), but we do not sell personal information (Selling).

Exercise of Rights

To request the cessation of sharing or deletion of information, please use the Device settings mentioned in Section 7 or contact the office in Section 12. We will not discriminate against Users for exercising their rights.

9. Information for Singapore Residents (PDPA)

In accordance with the Personal Data Protection Act (PDPA) of Singapore, we will provide notification of the purpose of acquisition, obtain consent, and implement reasonable security measures. Inquiries regarding withdrawal of consent or information access will be handled by the Data Protection Officer (DPO) listed below.

10. Protection of Minors' Information

We comply with COPPA and other applicable laws and do not knowingly collect information from children under the age of 13. Furthermore, we do not knowingly allow the use of the Service by persons under the age of 13.

11. Security Measures

To prevent the leakage, loss, or damage of personal information, we implement reasonable security measures such as access restrictions and encryption.

12. Contact Information and Data Protection Officer (DPO)

For inquiries regarding this Policy or the exercise of rights, please contact the following:

Ullucus Heaven Inc. Data Protection Officer (DPO)

Alvion Bldg., 1-9-10 Esakacho, Suita-shi, Osaka, 564-0063, Japan

Email: monpri_support@ullucus.com

13. Amendments to this Policy

We reserve the right to amend this Policy at any time. The amended Policy shall take effect at the time it is posted within the Service or on the official website. Your continued use of the Service after any amendments shall be deemed as consent to such changes.

Effective Date: February 18, 2026