Black Tower Studios Privacy Policy

This privacy policy was last modified on 12 September 2023.

Black Tower Studios (hereinafter referred to as "our company") establishes the following privacy policy (hereinafter referred to as "this policy") regarding the handling of users' personal information in the services provided on this website (hereinafter referred to as "this service").

  1. About Our Privacy Policy

1.1 The privacy of your Personal Information is important to Black Tower Studios. We respect your rights to privacy and rights under the Privacy Act and are committed to complying with the requirements of the Privacy Law in the collection and handling of your Personal Information.

1.2 This policy explains how we collect, retain, process, share, transfer, and handle your Personal Information and describes the kinds of Personal Information we collect, use, disclose, and our purposes for doing so.

1.3 We use some defined terms in this policy. You can find the meaning of each defined term at the end of this policy.

1.4 Personal Information is information that may be used to reasonably identify you. For example, your name, address, date of birth, gender, email address, and telephone number is generally considered to be Personal Information. Personal Information may also include information we collect about your individual preferences.

1.5 This policy applies to your Personal Information when you use our Website, and interact generally with us but does not apply to Third Party Sites. We are not responsible for the privacy policies or content of Third Party Sites.

1.6 For the avoidance of doubt, unless stated otherwise, this policy will govern our collection of your Personal Information irrespective of the forum.

1.7 This policy may be updated from time to time and the most up-to-date version will be published on our Website. We encourage you to check our Website periodically to ensure that you are aware of our current policy.

1.8 Your continued usage of our Website and/or services will be taken to indicate your acceptance of the terms of this privacy policy insofar as it relates to our Website.

  1. Why we collect Personal Information

2.1 When you visit our Website, we collect Personal Information so that we can provide you with products and services and improve and customize your experience with us. We only collect Personal Information if it is reasonably necessary for us to carry out our functions and activities.

2.2 The purposes for which we collect and hold your Personal Information include:

(a). to deliver our products and services to you;

(b). to manage our relationship with you, evaluate our business performance, and build our customer database;

(c). to respond to your requests and seek your feedback;

(d). to conduct research, compare information for accuracy and verification purposes, compile or analyze statistics relevant to the operations of our business;

(e). to facilitate our internal business operations, including fulfillment of any legal and regulatory requirements and monitoring, analyzing, and improving the performance and functionality of our Website and investigating breaches of or enforcement of any legal terms applicable to our Website;

(f). to protect our property, the Website, or our legal rights including creating backups of our business records;

(g). to manage risk and protect our Website from fraud by verifying your identity and helping to detect and prevent fraudulent use of our Website;

(h). for the direct marketing and promotional purposes as set out below; and

(i). to manage our business, including analyzing data collected from our Website concerning visits and activities of users on our Website including the Analytics Services. This analysis helps us run our Website more efficiently and improve and personalize your experience online.

  1. What Personal Information do we collect?

3.1 The type of personal information we collect depends on the type of interaction you have with us. In general, the types of personal information we collect may include:

(a). your name, address (postal and home), email address, telephone number(s), date of birth, and gender when you register with us;

(b). information from third-party sources such as data providers and credit organizations, where permitted by law, including public blockchain data such as your nominated public key for a digital asset wallet;

(c). details of the device you used to access any part of our website, including the carrier/operating system, connection type, IP address, and other information that may be automatically collected and used by us when you use our website, through the browser on your device or otherwise;

(d). demographic information;

(e). location data;

(f). your associations with others whose personal information we may collect or maintain;

(g). online payment details, which may include blockchain transaction data, third-party payment systems, credit or debit details of your bank account to process transactions contemplated by our Services; and

(f). transaction details relating to your use of our products, services, or rewards.

  1. 3.2 Telephone calls to us may also be recorded for training and quality assurance purposes.
  2. 4. With whom do we share Personal Information?

  3. 4.1 We may disclose personal information collected from you to

(a). to our affiliates, employees, officers, agents, contractors, other companies that provide services to us, sponsors, government agencies, or other third parties to fulfill the purposes for which the information was collected (as described in Section 2.2 of this Policy) or for any other purpose if that other purpose is closely related to the primary purpose for which the information was collected and an individual would reasonably expect us to disclose the information for that secondary purpose;

(b). to third parties who assist us in verifying the identity of our customers and clients and other software service providers who assist us in providing the services we provide to you;

(c). to third parties who help us analyze the information we collect so that we can administer, support, improve, or develop our business and the services we provide to you;

(d). to merchants and recipients of funds to identify you as the sender of the funds and to a party sending funds to you in connection with a transfer of funds to you;

(e). to third parties, including those in the blockchain and fintech industry, marketing and advertising sectors, to use your information to inform you about goods and services that may be of interest to you, in accordance with the Personal Information Protection Act of Japan and other relevant Japanese laws and regulations governing privacy and personal information;

(f). where disclosure is required by law or legal process or is requested by a government agency or other third party in response to a subpoena, court order, or other legal processes with which we are required to comply, including in relation to our obligations under the Act on Prevention of Transfer of Criminal Proceeds in Japan;

(g). to our professional advisers such as consultants, bankers, professional indemnity insurers, brokers, and auditors so that we can comply with our regulatory obligations and administer, support, improve, or develop our business;

(h). to debt recovery agencies who assist us in the recovery of debts owed to us;

(i). to any other person with your consent (express or implied); and

(j). to facilitate the sale of all or a substantial part of our assets or business or to companies with which we propose to merge or who propose to acquire us and their advisers.

4.2 In addition to the recipients listed above, we will disclose your personal information if we are required to do so by law or if the disclosure is made in connection with either the normal operation of our business in a manner that you would reasonably expect, for example, if such disclosure is incidental to the provision of IT services to our business or for the resolution of any dispute that may arise between you and us. This disclosure may involve the transfer of your personal information overseas.

4.3 In the event of a proposed reorganization or sale of our business (or part of our business), or if a company proposes to acquire or merge with us, we may disclose Personal Information to the buyer and its advisors without your consent, subject to compliance with the Privacy Act. If we sell the business and the sale is structured as a stock sale, you acknowledge that this transaction will not constitute a "transfer" of Personal Information.

5. How we collect and store data and transmit Personal Information

5.1 We generally collect and store information, including in paper, physical, and electronic form, that you provide when you communicate with us by telephone, e-mail, web-based form, letter, facsimile, or other means, including when

(a). you contact us by telephone

(b). we provide our services to you via telephone, email, or our website;

(c). we provide you with assistance or support for our products or services;

(d). you participate in our functions, events, or activities or on our social media pages;

(e). you request that we provide you with information about our products or services;

(f). you upload or submit information to us or our website; or

(g). you complete any forms that request information from you, including when you register with us, complete a survey, or provide feedback to us about our products or services.

5.2 Wherever possible, we will only collect information from you personally. However, we will also collect your personal information through our affiliates and third parties who provide services to us.

5.3 Please note that we use our own and third-party computer servers, including our website hosts, data backups, and payment gateway(s), which may be located overseas and your personal information is likely to be stored and transferred overseas as part of the normal operation of our business.

5.4 We also automatically collect information from your computer or mobile device when you browse our site. This information may include:

(a). the date and time of your visit;

(b). your domain;

(c). location;

(d). operating system;

(e). the server from which your computer or mobile device is accessing our site;

(f). your browser and version number;

(g). the search terms you entered to find or access our website;

(h). pages and links that you have accessed both on our website and on other websites;

(i). the last website you visited;

(j). the pages of our site that you access;

(k). the device you use to access our site; and

(l). your IP address.

5.5 Although we do not use some of this information to identify you personally, we may record certain information about your use of our site, such as the pages you visit and the time and date of your visit, that could potentially be used to identify you.

5.6 We may be able to identify you from information that is automatically collected during your visit(s) to our website. If you have registered an account with us, we may be able to identify you by your username and password when you log in to our site. In addition, we may be able to identify you if you access our site through links in an email we send to you.

5.7 The device you use to access our Site may collect information about you, including your location using latitude and longitude coordinates obtained through GPS, Wi-Fi, or cell site triangulation. For information about your ability to limit the collection and use of such information, please use the settings available on your device.

5.8 We may use statistical analysis software tools and software known as cookies that transmit data to third-party servers located overseas. To our knowledge, our analytics providers do not identify individual users or associate your IP address with any other data they may have.

6. How we protect your Personal Information

6.1 We will endeavor to take all reasonable steps to keep secure and protect any personal information we hold about you, including:

(a). securing our physical premises and digital storage

(b). using computer safeguards such as Secure Socket Layer (SSL) technology to ensure that your information is encrypted and transmitted securely over the Internet;

(c). implementing password protection and access controls on our information technology systems and databases to limit access and protect electronic information from unauthorized interference, access, modification disclosure; and

(d). performing regular backups of our electronic systems.

6.2 While we will take all reasonable steps to protect your personal information, no data transmission over the Internet can be guaranteed to be completely secure. We cannot and do not warrant the security of any information you transmit to us or from any online service.

7. Use of Cookies

7.1 When you visit our website or the website of any of our partners, we and our partners may use cookies and other tracking technologies ("cookies") to recognize you and customize your online experience. Cookies are small files that store information on your computer, mobile phone, or other device. They allow us to recognize you across different sites, services, devices, and/or browsing sessions. Cookies also help us customize online content and advertising, remember your preferences for future visits to the Site, measure the effectiveness of our promotions, prevent potential fraud, and analyze your and other users' interactions with the Site.

7.2 If you do not want us to use cookies to collect information about you while you are using our Site, you can set your browser to delete, disable, or block certain cookies.

7.3 You may be asked to consent to the use of cookies when you access certain parts of our Site, for example, when you are asked if you want the Site to "remember" certain things about you.

7.4 Certain aspects and features of the Site are only available through the use of cookies. If you disable cookies, your use of the Site may be limited or unavailable, or parts of our Site may not function properly when you use them.

8. Not identifying yourself

8.1 It may not be practicable to deal with you on an anonymous basis or by using a pseudonym.

8.2 We may be able to provide you with limited information if you do not identify yourself, but generally we will not be able to provide you with any information, goods, and/or services unless you identify yourself.

9. How to access or correct your Personal Information or make an inquiry or complaint

9.1 If you have any questions about this policy, wish to access or correct the personal information we hold about you or wish to make a complaint, please contact us in writing at

Email: or

Mail: Privacy Officer

304, Japan General Estate Otsuka Building

1-13-17 Kitaotsuka, Toshima-ku, Tokyo, Japan


9.2 We aim to acknowledge receipt of all privacy complaints from you within 10 business days and to resolve all complaints within 60 business days. If we are unable to resolve a complaint within this period, we will notify you of the reason for the delay and provide an estimate of when we expect to resolve the complaint.

9.3 In order to disclose information to you in response to a request for access, we may require you to provide us with certain information to verify your identity. There are exceptions under the Privacy Act that may affect your right to access your personal information - these exceptions include where (among other things)

(a). access would pose a serious threat to the life, health, or safety of an individual;

(b). access would have an unreasonable impact on the privacy of others;

(c). the request for access is frivolous or vexatious;

(d). the information relates to an existing or anticipated legal proceeding between you and us, and the information is not otherwise available through the discovery process;

(e). giving access would reveal our intentions with respect to negotiations with you;

(f). providing access would be unlawful;

(g). denying access is required or authorized by or under any Japanese law court or tribunal;

(h). the information relates to commercially sensitive decision-making; or

(i). providing access would interfere with law enforcement activities.

9.4 We may (depending on the request) charge you a fee to access the Personal Information. We will inform you of any fees payable for access to your Personal Information prior to processing your request. All requests for Personal Information will be processed within a reasonable time (within 60 calendar days of the request).

9.5 Users may request corrections, additions, or deletions (hereinafter referred to as "corrections, etc.") to their personal information held by our company if they find that it contains erroneous information. Such requests should be made according to the procedures established by our company.

9.6 We, upon determining that it is necessary to respond to a request from a user pursuant to the preceding paragraph, shall make the corrections, etc. to the relevant personal information without delay.

9.7 We will notify the user without delay when it has made corrections, etc. based on the provisions of the preceding paragraph, or when it has decided not to make corrections, etc.

10. Changes to this Privacy Policy

10.1 The contents of this policy can be changed without notice to users, except for matters that are stipulated separately in laws and regulations or in this policy.

10.2 Except in cases separately specified by our company, the revised privacy policy will take effect from the time it is posted on this website.

Game logo
Black Tower Studios logo