coly, Inc.(hereafter we, us, the Company) has adopted this privacy policy (hereafter “Privacy Policy”) to explain how we collect, store, and use the information collected in connection with the Company’s products and services including, but not limited to, the Company’s websites, applications for mobile platforms and devices (including third party applications utilizing the Services), web applications accessible on third party social networking services (SNS), game publisher and other networks and platforms(collectively, the “Services”).

By installing, using, registering to, or otherwise accessing any Services, you agree to this Privacy Policy (which is incorporated into the company’s Terms of Use) and to the processing, use, and disclosure of information as described herein.

The company reserves the right to modify this Privacy Policy from time to time as necessary. The Company will post all such changes together with the effective date for such updated Privacy Policy. By continuing to access or use the Services after  an updated Privacy Policy or The Company has provided you with notice of a modification, you are agreeing to be bound by the modified Privacy Policy. If the modified Privacy Policy is not acceptable to you, you may cease using the Services.

If you have any questions relating to this Privacy Policy or to any updates, please contact us using the form at

1.Collection of Personal Information and Non-identifying Information


Over the course of using the Services, the Company may ask you to provide certain personally identifiable information (“Personal Information”). The types of Personal Information that may be collected, processed or used may vary depending on the type of activity you take part in. Personal Information may include, but is not limited to, your name, nickname, email address, Services ID or other IDs, phone number, birthdate, gender, mailing address, credit card information, and shipping information. The Company will collect, use, transfer and disclose Personal Information according to this Privacy Policy.


The Company also collects non-identifying information (“Non-identifying Information”). For purposes of this Privacy Policy, Non-identifying Information is information that does not enable coly, Inc. to directly identify you. The types of Non-identifying Information that coly, Inc. may collect and use include, but is not limited to:

  1. Properties of your device, including, but not limited to IP address, Media Access Control (i.e. MAC) address and unique device identifier or other device identifiers (i.e. Device ID)
  2. Device software platform and firmware version
  3. Mobile phone carrier
  4. Location data such as zip code, postal code, area code and location
  5. Game progress including time spent playing, score and achievements
  6. Other non-personal data as reasonably required by coly, Inc. to enhance the Services. The Company may collect, use, transfer and disclose Non-identifying Information for any legal purpose.


The following are some situations that you make Personal Information available to the Company:

  1. Registration for Services, contests, promotions and special events
  2. Accessing or registering for Services using a third party ID, such as social networking sites or gaming services
  3. Subscribing to newsletters
  4. Purchasing a product or service via the Company’s online stores
  5. Using “tell a friend,” “email this page,” or other similar “share” features (in these cases the names and contact information of your friends etc. may also be collected)
  6. Requesting technical support or customer support
  7. Other areas of use where the Services require personal data for use or participation. This list is non-exhaustive and there may be other cases not included in this list.

2.Use of Information


Your Personal Information may be used for various purposes, including, but not limited to, the following:

  1. To help the Company develop, deliver, manage and improve the Services and advertising
  2. To serve ads that contain links to services, websites or applications. Additionally, the Company may further utilize your Device ID to track clicks or other ad fulfillment metrics
  3. To provide customer and technical support
  4. For market research purposes that support the Company’s abilities to produce a more valuable service to its users
  5. To send messages with informative or commercial content about the Company, the Services, or third party products and services that the Company believes may be of relevant to you
  6. To enable the Company to update you with regards to its latest Services announcements, software updates, upcoming events, etc.
  7. To audit and analyze data to improve the Services and customer communications
  8. To send important notices, such as communications about your purchases and changes to our Terms of Use, this Privacy Policy, or other Service-specific policies
  9. As otherwise permitted under this Privacy Policy.


Personal Information and Non-identifying Information may be used alone or in tandem with information collected from other Services users for any purpose permitted under this Privacy Policy and by law. Some non-identifying Information would be considered part of your Personal Information if it were combined with other identifiers in a way that enables you to be personally identified but would be considered as Non-identifying Information when considered alone or combined with other Non-identifying Information.:


Certain features of the Services may be able to connect to a SNS (e.g., X( formerly Twitter)). If you use such features or otherwise link your Services account to an SNS, Personal Information and other information that you submit to the SNS may be collected and used by the Company in accordance with this Privacy Policy, and you hereby consent to such collection and its use. The Company’s access to such Personal Information and other information will also follow the rules as stipulated in the privacy settings of your SNS account, if any. The Company may also use Personal Information and other information that you have provided or made accessible to the SNS to help you establish social connections with other Services users.:

3.Disclosure and Transfer of Information


Personal Information and Non-identifying Information may be shared, disclosed, or transferred in accordance with applicable law and this Privacy Policy.


The Company may use agents, contractors or third party service providers (including but not limited to credit card processors, email service providers, software developers, user account authenticators, cloud storage providers, virtual currency service providers, administrative service providers, crowd-sourcing service providers, and shipping agents). The Company has the right to share your Personal Information and Non-identifying Information as necessary for such third parties to provide their services to the Company. The Company is not liable for the acts and omissions of these third parties, except as mandated by law.


The company may include in the Services tools, including those from third party service providers, which may enable the Company or these third parties to analyze your and other users’ information. This information may include your UDID, Media Access Control address, mobile carrier, IP address, International Mobile Equipment Identity Number, version of iOS or Android, specific type of device, and session start and end times. The Company and such third parties may use this information to detect the user’s country and otherwise analyze the user’s engagement. The third parties may have access to Personal Information in connection with their services but they will not be permitted to use such information, other than in an anonymized, aggregated form, for any purpose other than the provision of the services.


The Company may disclose Personal Information to third parties as required by law enforcement or other government officials or judicial authorities in connection with litigation, an investigation of fraud, intellectual property infringement, or other activity that is or may be illegal or may expose the Company, its users, you or third parties to legal liability.


The Company may also disclose your Personal Information to third parties if it believes that doing so is appropriate to comply with the law, to enforce or exercise the Company’s rights, or to protect the Company’s, the users’ or third parties’ property, rights or safety.


The Company may share Non-identifying Information and aggregate and anonymous information about you with advertisers, publishers and other third parties with whom we have relationships. The information that the Company shares with these third parties will only be used in the form of Non-identifying Information to support user trend analyses, demographic profiling or other similar activities.


The Company may also share your username, email address or Device ID (i.e. Specific Shared Data) with specific third party publishers who have designed applications utilizing the Services, as well as other business partners (i.e. Preferred Partners) so that said parties may assist the Company in providing you with aspects of the Services for which you provided such Specific Shared Data and to use this Specific Shared Data to provide you with additional information and/or marketing materials about these kinds of third party applications and other products and services so that you may further enhance your use of the Services. Additionally, if you make an inquiry to the Company regarding a third party publisher’s application, the Company may send Specific Shared Data as well as the inquiry to the applicable third party publisher.


In the event that The Company undergoes a business transition, such as a merger, acquisition by another company, or sale of all or a portion of its assets, or undergoes bankruptcy, reorganization, liquidation or analogous proceedings, the Company may transfer all of your information, including Personal Information, to the successor organization in such transition or as a part of such proceedings.


In addition, the Company may also disclose your Personal Information with other third parties when we have received your consent to such disclosures.:

4.Disclosure of Information Within the Services
By creating an account you gain the ability to create your own profile, connect with other users of the Company’s Services, and send messages or transmit information through a variety of methods. Any communications you have via the Services (including through Company applications, websites, or third party publishers utilizing the Services in their own applications or websites) may reveal your nickname and the content of your communications. Doing so will make this information public to other users. The Company does not assume responsibility, and disclaims liability for, for the activities of other users or third parties to whom you provide your Personal Information or otherwise interact.

5.Location-Based Services
For location-based Services, the Company may collect, use, and share precise location data, including the real-time geographic location of your computer or mobile device. However, unless you explicitly opt-in to permit the use and sharing of your Personal Information regarding your geographic location, your location data will only be collected and used anonymously in a form that does not personally identify you. When you opt in to location services of a third party publisher’s application which utilizes the Services, the Company will share your geographic location with such third party publishers and related application providers in connection with their location services. Please note that some location-based services may require your Personal Information for the feature to work as intended.

6.Cookies, Web Beacons and Other Technologies


A “cookie” is a data file that is transferred to a user’s computer and is intended to identify that computer. Cookies are used to maintain information about a user’s visit to an application, website or game, such as user names, passwords and individual preferences. The Services may send cookies to your computer when you access the Services. Information contained in a cookie may be linked to your Personal Information. That information may be used for a variety of purposes including improving the quality and ease of use of the Services, managing and sending advertising, studying traffic patterns, and understanding the effectiveness of marketing communications.


Some of the Services may also collect information using “web beacons,” “pixel tags, “gifs” or similar means (referred to collectively as “Pixel Tags”) in our Services to collect usage, demographic, location, or other data. A Pixel Tag is a single pixel not generally visible to the user which may then be associated with cookies or with the user’s hard drive. Through the use of Pixel Tags the Company can do things such as counting users, delivery of branded services, and gathering data to assess the effectiveness of promotional campaigns.


The Services may include third party advertisements. These ads may be served by third party advertising companies that deliver cookies to your computer, allowing these companies to track the ads. These companies will consequently be able to recognize your computer when they send you an advertisement. These advertisers may use information about your visits to the Services in order to provide advertisements about goods and services that may be of interest to you.


You may at any time disable cookies by changing the options in your browser to stop accepting cookies or to prompt you before accepting a cookie from the pages you visit. If you do not accept cookies, however, you may not be able to view or use all portions of the Services due to limited functionality.

7.Security of Your Information


It is important that you protect and maintain the security of your account and that you immediately notify the Company of any unauthorized use of your account. If you forget the password to your coly store account, the Services allows you to request that instructions be sent to you that explain how to reset your password. When you sign into your account or enter payment information (such as a credit card number), coly, Inc. encrypts the transmission of that information using secure socket layer technology (i.e. SSL).


While the Company takes reasonable precautions against possible security breaches of our Services and customer records, no website or internet transmission can be completely secure. The Company does not guarantee that unauthorized access, hacking, data loss, or other breaches will never occur. The Company strongly recommends that you take steps to keep your personal information safe (including your account password), and to log out of your account after use. In addition, if your SNS account is hacked, it may lead to unauthorized use of Services you have procured so be careful to keep your account information secure.


The transmission of information over the internet is not completely secure. The Company cannot guarantee the security of your data while it is being transmitted and any transmission is at your own risk.

8.Changing or Removing Information


You may at any time request that your Personal Information be changed or deleted by following the process provided in the applicable Services and we will take all reasonable measures to promptly comply with such requests. If you delete all of your information, your account may become deactivated. If you wish to stop receiving emails, you may opt-out of receiving promotional emails by following the instructions in those emails. If you opt-out, the Company may still send you non-promotional emails, such as emails about your accounts or your ongoing business relations with coly, Inc.


You may also contact the Company through our contact page at to request the deletion of your Personal Information from the Company’s database. The Company will use reasonable efforts to honor your request. However, the Company may retain an archived copy of your records as required by law or for legitimate business purposes.


Specific Shared Data cannot be retrieved from Preferred Partners after its disclosure.


When you share information with other users through the communication channels of the Services, you should expect to have any ability to modify or remove such communications.

9.Links to Other Websites and Services
The Services may contain links to other websites and online services or offers from third parties, such as third party advertisers. Should you choose to participate in offer-linked information requests or click(or tap) an advertisement or other third party link, you may be directed to that third party’s website or service and/or be prompted to provide Personal Information. The Company is not responsible for the privacy practices or the content of such websites or services. If you have any questions about how these other websites or services use your information, please review their policies and contact them directly.

10.International Transfer of Information
The Company may transfer information (including Personal Information) that is collected about you to its affiliates or to other third parties that may be outside of your country. If you are located in the European Union, other countries and jurisdictions may have laws governing data collection and use that are less strict or otherwise differ from the laws where the information may be transferred or used. Please note that, by accessing or using the Services, you are transferring information and allowing the Company or others to transfer information, including personal information, to a country that may not have the same data protection or privacy laws as your jurisdiction. By using the Services, you consent to the transfer of information to countries outside of your jurisdiction and the use and disclosure of information about you, including Personal Information, as described in this Privacy Policy.

11. Policy Toward Children
The Services are not intended for children under the age of 13 and the Company does not knowingly collect any Personal Information from such children. If the Company discovers that it has inadvertently collected Personal Information from children, it will take all reasonable measures to erase such information from its systems and records as soon as possible.

12.California Privacy Rights
California Civil Code Section 1798.83 permits customers of coly, Inc. who are California residents to request certain information regarding our disclosure of personal information (as defined in the Code) to third parties for their direct marketing purposes. If you are a California resident and have provided the Company with personal information within the last year, you may make such a request by contacting us with the form available at
. Please make the email’s subject “California Privacy Rights”.

13.Contact Information
If you have any questions, comments or concerns regarding this Privacy Policy, please contact us at

coly, Inc.
Sumitomo Fudosan Shin-Akasaka Bldg. 5F, 4-2-6 Akasaka, Minato-ku, Tokyo 107-0052, Japan
Anna Nakajima

Last Updated: December 13, 2023