GDPR Notice

This section supplements our Privacy Policy for players in the European Economic Area, the United Kingdom, and Switzerland. If anything in this section conflicts with the main Privacy Policy, this section prevails for those players.


4.1 Data controller

Otsunuma Studios

EU Representative (Article 27 GDPR): Not currently appointed — will be appointed if required based on processing volume.

UK Representative: Not currently appointed.


4.2 What data we process and why

Please see Sections 1.2 and 1.4 of our Privacy Policy for categories of personal data and processing purposes.


4.3 Legal bases

As set out in Section 1.5:

  • Contract — account creation, delivering the game, processing purchases.
  • Legitimate interests — fraud prevention, security, cheat detection, non-personalized analytics, product improvement. You can object at any time.
  • Consent — personalized advertising, optional analytics, newsletters, processing where required by the e-Privacy Directive or PECR (UK).
  • Legal obligation — tax records, responding to lawful requests, complying with consumer and gambling laws.

4.4 Your rights under GDPR / UK GDPR

You have the right to:

To exercise any of these rights, email hello@otsunuma.com. We respond within 30 days (extendable to 90 days for complex requests). There is no fee unless your request is manifestly unfounded or excessive.

  • access — a copy of your personal data;
  • rectification — correct inaccurate data;
  • erasure — delete your data, where the legal bases allow;
  • restriction — limit our processing in certain cases;
  • objection — object to processing based on legitimate interests or direct marketing;
  • portability — receive your data in a machine-readable format;
  • withdraw consent — at any time, without affecting the lawfulness of prior processing;
  • not be subject to solely automated decisions that produce legal or similarly significant effects — we do not currently carry out such decisions;
  • lodge a complaint with your national data-protection authority.

4.5 International transfers

Data may be transferred outside the EEA/UK to India and other countries where our service providers operate. We use Standard Contractual Clauses approved by the European Commission (and the UK Addendum where relevant), plus supplementary measures where needed, to protect your data. You can request a copy of the transfer safeguards by emailing hello@otsunuma.com.


4.6 Retention

We keep personal data only as long as needed for the purposes described in the Privacy Policy (Section 1.8) or as required by law.


4.7 Children in the EU/UK

We do not knowingly process the personal data of children below the age of digital consent in their country (13-16, depending on the member state; 13 in the UK) without verifiable parental consent. We do not serve personalized ads to children.


4.8 Complaints

If you believe we've mishandled your data, please contact hello@otsunuma.com first. You also have the right to complain directly to your national supervisory authority — for example:

  • Ireland: Data Protection Commission (dataprotection.ie)
  • Germany: your local Landesdatenschutzbeauftragte
  • France: CNIL (cnil.fr)
  • United Kingdom: Information Commissioner's Office (ico.org.uk)

4.9 Changes

We will notify EU/UK players of material changes at least 30 days before they take effect, where feasible.


4.10 Contact

If you have any questions about this Policy, please contact us at hello@otsunuma.com.

---